E-invoicing in Germany: who is affected and from when, small businesses included

Since 1 January 2025, Germany has been phasing in mandatory electronic invoicing between businesses. The rule sits in § 14 UStG (the VAT act) as amended by the Wachstumschancengesetz of March 2024, with transition periods in § 27 UStG and the details in a letter of the Federal Ministry of Finance (BMF) of 15 October 2024. This guide says who is affected, from when, and what the exceptions are. It is not legal advice: for a concrete case, the law and the BMF letter prevail.

The definition first

An e-invoice in the legal sense is an invoice issued, transmitted and received in a structured electronic format that allows electronic processing and complies with the European norm EN 16931, or is interoperable with it. XRechnung and ZUGFeRD (from profile BASIC) meet the definition; a PDF sent by e-mail does not, however neat it looks. Everything that is not an e-invoice is called an other invoice ("sonstige Rechnung"): paper, PDF, image files.

Who and from when

The obligation applies to domestic B2B transactions: both the supplier and the customer are businesses established in Germany, and the supply is taxable in Germany. Invoices to consumers (B2C) are not covered, nor are supplies to businesses abroad.

Date	What changes
1 January 2025	Every business must be able to receive e-invoices. An e-mail inbox is enough; the sender does not need the recipient's consent any more.
2025 and 2026	Transition: suppliers may still issue paper or, with the recipient's consent, PDF and other non-structured formats. EDI procedures may continue.
1 January 2027	Businesses whose total turnover in 2026 exceeded EUR 800,000 must issue e-invoices for domestic B2B supplies. Smaller businesses may keep issuing other invoices until the end of 2027. EDI is still allowed until the end of 2027.
1 January 2028	All businesses must issue e-invoices for domestic B2B supplies. EDI formats must comply with EN 16931 or be interoperable with it.

The turnover threshold refers to the previous calendar year and to the business as a whole, not to a single customer or product line.

Exceptions

Even after 2028 an e-invoice is not required for:

• small-amount invoices up to EUR 250 gross (§ 33 UStDV);
• tickets that serve as invoices (§ 34 UStDV);
• supplies that are VAT-exempt under § 4 Nr. 8 to 29 UStG (financial services, most medical and educational services, letting of property among others);
• invoices to consumers and to businesses not established in Germany.

For these, a paper or PDF invoice remains possible; an e-invoice is always allowed.

The special case of Kleinunternehmer

Small businesses under the Kleinunternehmerregelung (§ 19 UStG) do not charge VAT. With the Jahressteuergesetz 2024 the legislator settled their position: a Kleinunternehmer is not required to issue e-invoices (§ 34a UStDV) and may keep sending other invoices without a time limit. A Kleinunternehmer must however be able to receive e-invoices like everyone else since 1 January 2025, because a supplier subject to the obligation must send an e-invoice regardless of the customer's status. Practically: an e-mail address and a tool to read the XML, such as the Factur-X viewer, are enough. Note that the turnover limits of the Kleinunternehmerregelung themselves changed on 1 January 2025 (EUR 25,000 for the previous year, EUR 100,000 in the current year); the BMF pages cite the current figures.

Public bodies are a separate matter

The B2B rule above is a VAT rule. Invoices to public bodies have followed a different track since 2020: the E-Rechnungsverordnung of the federal government and the corresponding regulations of the Länder require e-invoices in most public procurement, typically XRechnung with a Leitweg-ID. Whether a public body is your customer determines the format and the portal, not the turnover threshold.

What to do now

1. Receiving: make sure incoming XML and hybrid PDFs are opened, read and archived as received (the XML is the invoice; keep it unchanged, in a form that stays machine-readable, for the retention period).
2. Issuing: check with your software vendor which formats it produces; XRechnung and ZUGFeRD in the EN 16931 profile are the safe choices, see XRechnung vs ZUGFeRD.
3. Quality: validate before sending. A structurally valid file that violates a business rule (a missing buyer reference, a VAT breakdown that does not add up) will be rejected by the recipient's software. The XRechnung validator and the ZUGFeRD validator run in the browser and explain every rule they report.

The Germany country page keeps the calendar and is updated when the rules change.

Sources

• § 14 UStG (e-invoice definition and obligation): gesetze-im-internet.de/ustg_1980/__14.html
• § 27 UStG (transition periods): gesetze-im-internet.de/ustg_1980/__27.html
• §§ 33, 34 and 34a UStDV (small amounts, tickets, Kleinunternehmer): gesetze-im-internet.de/ustdv_1980
• BMF letter of 15 October 2024 and FAQ on the e-invoice: bundesfinanzministerium.de
• Wachstumschancengesetz (BGBl. 2024 I Nr. 108): recht.bund.de
• E-Rechnungsverordnung for federal public bodies: gesetze-im-internet.de/erechv