Fiscal subject related
Invoicing in Germany is changing fundamentally. With the introduction of mandatory electronic invoicing (e-invoicing) in B2B transactions, Germany is moving away from traditional paper and PDF invoices.
- Since January 1, 2025, companies must be able to receive electronic invoices.
- From 2027, companies will be required to send structured e-invoices.
- This makes 2026 a critical preparation year, during which businesses must update systems, processes, and internal responsibilities.
The obligation is based on the Growth Opportunities Act, which amended Section 14(2) of the German VAT Act (UStG). It introduces mandatory e-invoicing for domestic B2B transactions between businesses established in Germany.
A business is considered domestic if it has:
- its registered office,
- place of management, or
- a permanent establishment involved in sales in Germany.
Foreign businesses that are only VAT-registered in Germany but have no permanent establishment are not required to issue German e-invoices, but may still receive them.
Since January 1, 2025, all affected businesses must be able to receive e-invoices.
Transitional rules apply:
- During 2026, businesses may still issue paper or PDF invoices.
- Businesses with annual turnover below €800,000 may continue using non-e-invoice formats until 31 December 2027.
- Until the end of 2027, invoicing via EDI is allowed if the customer agrees.
Exemptions:
- Small-value invoices and travel tickets are excluded.
- Small businesses do not need to issue e-invoices, but must still be able to receive them.
An e-invoice is not a PDF sent by email.
To qualify, it must:
- be issued, transmitted, and received in a structured electronic format,
- allow automated electronic processing,
- comply with the European standard EN 16931.
In Germany, the most common formats are:
- XRechnung (fully structured data),
- ZUGFeRD (structured data + readable PDF). Other European formats (e.g. Factur-X) are allowed if they meet the standard.
By 2026, companies should ensure they can:
- create structured e-invoices compliant with EN 16931,
- send and receive invoices via approved electronic channels,
- align formats and processes with customers and suppliers,
- consider both German rules and future EU requirements.
Although full automation is not legally required yet, mandatory e-invoicing creates a strong basis for process standardisation and efficiency.
Implementing e-invoicing affects:
- finance and tax,
- IT systems,
- operational business processes.
It requires coordinated planning across departments, especially in procure-to-pay and order-to-cash processes. The level of effort depends on how digitalised the company already is.
2026 is the year to act:
- The legal framework is already in place.
- Mandatory sending of e-invoices starts in 2027.
- EU-wide digital VAT rules are coming next.
Companies that prepare in 2026 will:
- avoid compliance risks,
- ensure invoices are accepted and paid smoothly,
- modernise their invoicing processes,
- and be better prepared for future EU requirements.
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