Germany has clarified that small businesses under Section 19 UStG are exempt from issuing e-invoices even after the 2028 mandate, allowing continued use of paper or PDF invoices. However, they must still be able to receive, process, and store structured e-invoices from January 1, 2025, as part of the phased transition to full digital B2B invoicing.
Germany Clarifies E-Invoicing Rules for Small Businesses Ahead of 2028 Mandate
Public
Germany
Author: Ivana Picajkić
Category:
Fiscal subject related
Views:
116
Content accuracy validation date:
21.04.2026
Content accuracy validation time:
08:16h
Germany has confirmed how new e-Invoicing obligations will apply to small businesses, providing partial relief while still imposing key compliance requirements.
Under the updated framework, small businesses defined under Section 19 of the German VAT Act (UStG) are not required to issue e-Invoices, even after the full mandate takes effect in 2028. They may continue using paper or PDF invoices for their outgoing transactions.
However, the rules introduce an important obligation: all businesses, including small ones, must be able to receive and process structured e-invoices from January 1, 2025. This includes handling XML-based formats such as XRechnung or ZUGFeRD and storing them electronically for up to eight years in line with GoBD requirements.
The broader rollout of e-invoicing will take place in phases. Larger companies must begin issuing e-invoices for B2B transactions in 2027, while full mandatory e-Invoicing for all businesses will apply from 2028, effectively eliminating paper and PDF invoices for B2B transactions.
Although small businesses are exempt from issuing e-Invoices, authorities and market trends suggest that voluntary adoption is beneficial, as many companies are already automating invoice processing and may prefer structured formats.
In summary: small businesses avoid the burden of issuing e-invoices but must still adapt their systems to receive and manage them, marking a significant shift toward full digital invoicing across Germany.
Other news from Germany
New webinar was uploaded: Recorded Webinar: Are You Audit-Ready? Retail Tax Checks in Germany, France & Italy
Author: Ivana Picajkić and Vukasin Santo
Tax audits are increasingly important in European retail due to high transaction volumes and evolving compliance rules. With different fiscal systems in Germany, France, and Italy, understanding audit focus areas is essential. This webinar covers key audit frameworks, differences, and practical compliance insights for retailers. Read more
Subscribe to get access to the latest news, documents, webinars and educations.
Already subscriber? Login
New event was created: Reminder - Join our free webinar: Are You Audit-Ready? Retail Tax Checks in Germany, France & Italy
Public
Author: Ivana Picajkić and Vukašin Santo
Tax audits are becoming an increasingly important part of modern tax systems across Europe, especially in the retail sector where transaction volumes are high and compliance requirements are constantly evolving. With different fiscalization models in place across Germany, France, and Italy, understanding what authorities actually check during tax audits is essential for retailers and software pro... Read more
German Court Clarifies No Right to Final Meeting in VAT Fraud Investigations
Germany
Author: Ivana Picajkič
The German Federal Fiscal Court ruled that taxpayers are not entitled to a final meeting during a VAT audit once tax evasion proceedings are initiated. At that point, the procedure shifts from a standard audit to a criminal tax investigation, where different rules apply and procedural rights are more limited. Read more
Subscribe to get access to the latest news, documents, webinars and educations.
Already subscriber? Login
Germany Updates VAT Registration Certificate Rules (VAT 1 TN)
Germany
Author: Ivana Picajkić
Germany introduced a new standardized VAT registration certificate (VAT 1 TN), replacing previous guidance. The certificate serves only as proof of VAT registration, is valid for up to one year, and can be issued electronically without signature. The update mainly simplifies procedures and supports digitalization and cross-border VAT use. Read more
Subscribe to get access to the latest news, documents, webinars and educations.
Already subscriber? Login
New event was created: Join our free webinar: Are You Audit-Ready? Retail Tax Checks in Germany, France & Italy
Public
Author: Vukašin Santo and Ivana Picajkić
Tax audits are becoming an increasingly important part of modern tax systems across Europe, especially in the retail sector where transaction volumes are high and compliance requirements are constantly evolving. With different fiscalization models in place across Germany, France, and Italy, understanding what authorities actually check during tax audits is essential for retailers and software pro... Read more
New document was uploaded: Tax Audit in Germany
Germany
Author: Ivana Picajkić
The purpose of this document is to explain the rules governing the tax audit regime in Germany, including the legal framework, the main focus areas of a tax audit, and the procedures followed by the tax authorities. It also outlines the increasing importance of digital data access and audit techniques. Read more
Subscribe to get access to the latest news, documents, webinars and educations.
Already subscriber? Login
Germany Expands X-Rechnung as the Core of Its E-Invoicing System
Public
Germany
Author: Ivana Picajkić
Germany
Author: Ivana Picajkić
Germany is expanding the role of XRechnung as a core structured e-invoicing format, moving from public-sector use to a mandatory standard for domestic B2B transactions between 2025 and 2028, based on EU Directive 2014/55/EU and national legislation. Businesses must adapt their systems and processes to handle XML-based invoices, ensure compliance with EN 16931 standards, and manage proper transmiss... Read more