Since 1 January 2025, German businesses must be able to receive structured electronic invoices for domestic B2B transactions. The requirement to send e-invoices is now coming and will be introduced in phases: larger businesses must comply from 1 January 2027, and most other businesses from 1 January 2028. The reform is part of Germany's Growth Opportunities Act (Wachstumschancengesetz) and helps businesses prepare for digital VAT compliance and future European reporting rules.

Through one connected solution, Descartes helps businesses manage the challenges of e-invoicing requirements in Germany and other countries. Linking ERP, accounting, and back-office systems with e-invoicing networks and trading partners, the solution makes it easier to exchange compliant invoices across markets and takes away the worry about separate processes for each country.

Topic	What Does the German E-Invoicing Mandate Mean?
Status	Businesses must be able to receive structured e-invoices since 1 January 2025. As of 1 January 2027, businesses with more than €800,000 in annual turnover must start sending e-invoices. Most other businesses must be ready from 1 January 2028.
Who is affected?	Businesses established in Germany that exchange domestic B2B invoices. The mandate generally applies when both supplier and buyer are established in Germany.
Network	Germany does not require businesses to use one specific network. Invoices can be sent through Peppol, EDI, ERP integrations, email, or other valid electronic channels.
Formats	Structured EN 16931-compliant formats, including XRechnung, ZUGFeRD, Peppol BIS, and certain approved EDI formats.
PDF invoices	During the transition period, PDFs may still be used in certain situations with recipient consent. A PDF by itself is not a compliant e-invoice under the German mandate.
B2G invoices	E-invoicing for public sector entities remains mandatory through Chorus Pro.
B2C and international invoices	B2C invoices are outside the scope of the domestic B2B mandate. Cross-border transactions are currently excluded from the German B2B requirement.
Digital reporting	Germany's current reform focuses on structured e-invoicing rather than real-time invoice reporting. Future alignment with EU ViDA requirements is expected.
Penalties	Standard VAT and invoicing rules apply. If businesses cannot receive or send the right type of invoice when required, they will face VAT deductions, audits, or compliance issues.

What Is Mandatory Today?

Since 1 January 2025, all businesses within scope must be capable of receiving structured electronic EN 16931-compliant invoices. Refusing compliant electronic invoices from trading partners is no longer allowed.

The obligation to send compliant e-invoices is being phased in:

1 January 2027: Businesses with previous-year turnover over €800,000 must issue structured e-invoices for domestic B2B transactions.

1 January 2028: The e-invoicing obligation become applicable to most remaining businesses covered by the mandate.

Which companies must comply with Germany’s B2B e-invoicing mandate?

The German mandate generally applies to domestic B2B transactions where both parties are established in Germany. It covers companies, partnerships, sole traders, and other taxable persons conducting business transactions subject to German VAT rules.

Certain transactions remain outside the scope, including:

• B2C transactions.
• Many cross-border transactions.
• Certain VAT-exempt transactions.
• Small-value invoices under €250.

Specific travel and transport ticketing situations.

XRechnung, ZUGFeRD and EN 16931

Germany does not use a central clearance model. Instead, businesses can exchange invoices directly through approved electronic channels, as long as the invoices are in a structured format that meets the European EN 16931 standard.

The most common formats include:

XRechnung

Germany's national e-invoicing standard based on structured XML. It is mandatory for many B2G invoicing scenarios and widely used throughout the German market.

ZUGFeRD

A hybrid format combining a human-readable PDF with embedded structured XML data. It enables automated processing while retaining a visual invoice representation.

Peppol BIS

A standardized e-invoicing format aligned with EN 16931 that can be exchanged through the Peppol network, helping multinational organizations automate and scale invoicing processes across borders.

What About B2G, B2C and International Invoices?

B2G

Electronic invoicing for federal government authorities has been mandatory since 2020. Suppliers typically submit invoices in XRechnung format using government-approved channels and platforms.

B2C

Invoices issued to private consumers remain outside the scope of the domestic B2B e-invoicing mandate.

International

Cross-border transactions are generally not included in the current German domestic B2B mandate. However, businesses should prepare for future EU-wide digital reporting and e-invoicing requirements associated with ViDA.

Germany's Rollout Timeline

1 January 2025

All in-scope businesses must be capable of receiving and processing structured electronic invoices.

2025-2026 Transition Period

During the transition period, businesses are allowed to use paper and PDF invoices in certain situations, giving them time for getting systems and processes ready.

1 January 2027

Businesses with turnover above €800,000 must start sending structured e-invoices.

1 January 2028

Structured electronic invoicing becomes the standard to send most domestic B2B e-invoices.

Preparing for Future Digital Reporting Requirements

Germany's current initiative does not introduce a continuous transaction control (CTC) clearance model or real-time invoice reporting. However, the reform establishes the structured invoice foundation needed to support future reporting obligations and potential alignment with the EU's ViDA framework.

Organizations implementing e-invoicing today will be better positioned to adapt to future digital VAT reporting requirements.

Practical E-invoicing Checklist for Businesses

1. Get a clear picture of all invoice flows, including domestic B2B, B2G, B2C, and cross-border invoices.
2. Ensure that ERP and accounting systems are capable of receiving EN 16931-compliant invoices.
3. Confirm that your systems support XRechnung, ZUGFeRD, Peppol BIS, and compliant EDI formats.
4. Ensure invoice archiving processes meet German compliance requirements.
5. Test inbound and outbound invoice workflows with customers and suppliers.
6. Review exception handling, validation rules, and invoice status processes.
7. Get finance, tax, procurement, and IT teams ready for the deadlines to send e-invoices.
8. Monitor ViDA and German tax authority developments. 

How Descartes Helps with E-Invoicing in Germany

Descartes assists organizations with connecting ERP, finance, procurement, and back-office systems with customers, suppliers, and e-invoicing networks through one connected approach.

Our solution provides:

• Expertise to handle XRechnung, ZUGFeRD, Peppol BIS, and other compliant formats.
• Peppol connectivity through a certified access point.
• Automated sending and receiving of structured electronic invoices.
• Integration with ERP, accounting, WMS, procurement, and financial systems.
• Multi-country support for European and global e-invoicing compliance.
• Scalable infrastructure that can adapt to future reporting requirements.
• Expert support during implementation and onboarding.

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