Does the obligation apply to you?
The obligation attaches to the individual supply, not to the company as a whole. Three conditions have to hold together, and the same business can be inside the rules for one invoice and outside them for the next.
Both sides are established in Germany
Seller and buyer have their seat, their management or a permanent establishment in Germany that takes part in the supply. A company holding nothing more than a German VAT registration is a case to check with a tax adviser.
It is a supply between businesses
The buyer acts in a business capacity. Invoices to consumers stay outside the obligation entirely, however large the amount, and the duty to receive does not reach private customers either.
The supply is not on the exemption list
Invoices up to EUR 250 and transport tickets remain outside. So do cross-border supplies, which follow the rules of the country concerned rather than the German ones.
Where all three hold, the invoice has to be structured. Which formats qualify, how XRechnung and ZUGFeRD differ and why a PDF on its own is not an e-invoice is set out on the page what is an electronic invoice.
The three dates
The obligation to receive and the obligation to issue are separate, and they arrive at different times. The date that decides your own project is the second one.
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Receive e-invoices
Every business established in Germany has to be able to receive structured e-invoices for domestic business-to-business supplies. This applies regardless of size, and it applies to businesses under the small-entrepreneur scheme as well.
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Issue based on turnover
Businesses whose turnover in the previous calendar year exceeded EUR 800,000 have to issue structured e-invoices. The figure that decides this is the 2026 turnover, and it is known before the obligation starts.
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Issue in domestic B2B
The obligation to issue applies to every remaining business in domestic B2B.
Outside the obligation
- Invoices up to EUR 250
- Transport tickets
- Invoices to consumers
- Cross-border supplies, which follow their own rules
Easy to get wrong
- Small entrepreneurs do not have to issue, but they do have to be able to receive, and that has applied since January 2025.
- The threshold is per legal entity, not per group. A small subsidiary of a large parent may not be obliged in 2027.
- Being outside the issuing obligation is temporary. Everyone issues from 2028, so the distinction decides one year, not the project.
Which format to use
The law names the European standard, not a product. Two formats cover almost all of German practice, and the recipient decides which one arrives.
XRechnung
Plain XML, in UBL or CII syntax. Mandatory towards German public authorities and accepted by many companies. The productive version is 3.0.2; which version applies comes from the recipient.
ZUGFeRD and Factur-X
A PDF/A-3 document with the XML embedded inside it. People read the PDF, systems read the XML, and the XML is the binding part. Common between businesses.
Where are you sending to?
The law is the floor. What decides whether an invoice is paid is the set of requirements the recipient adds on top of it, and those differ sharply between public authorities and large companies.
Public authorities
XRechnung, a Leitweg-ID that identifies the receiving authority, and submission through ZRE, OZG-RE, the portal of the federal state or the Peppol network. The rules differ by state.
Large companies
What Volkswagen, Siemens, Deutsche Telekom, BMW, REWE, EDEKA and Deutsche Bahn expect on an invoice: accepted formats, the references that identify the order, and the delivery route each one has set out.
See the requirements by company
An invoice can conform to EN 16931 and still be rejected, because the buyer needs references the standard leaves optional.
Common validation rules in Germany
Regardless of the buyer, an invoice has to pass the rules of EN 16931 and the German usage specification. Each of these is a common reason for a file to come back.
Invoice totals must match exactly
The sum of the line amounts plus VAT equals the invoice total. A rounding difference of one cent is enough to fail the check.
Date must follow ISO 8601 format
YYYY-MM-DD in the structured data, whatever the visible document shows.
Invoice number must be unique
A number used twice is rejected as a duplicate, and some recipients narrow that to once per calendar year.
EndpointID must include a valid scheme identifier
An endpoint or party identifier needs its scheme, a GLN for instance with 0088.
All address fields must be complete
Street or PO box, town, postal code and country code, on both sides of the invoice.
Missing mandatory references leads to rejection
An order number for a company, a Leitweg-ID for a public authority. Formally optional in the standard, mandatory in practice.
How to prepare an invoice for Germany
Five steps, in the order in which they tend to block each other. Open a step for the detail.
BT-10; B2B follows the format the buyer asks for, with the purchase order number in BT-13. Establish at the same time which obligation applies to you: the threshold is measured per legal entity on the previous calendar year.BT-13, buyer reference BT-10, buyer accounting reference BT-19, and complete VAT totals. Identifiers need their scheme, a GLN for instance with 0088.Where it usually stalls is not the format. It is master data without identifiers, corrections nobody tested, and an agreement with the recipient that was never written down.
Frequent questions
What comes up most often about the German rules.
How is the EUR 800,000 threshold measured?
On the turnover of the previous calendar year, per legal entity rather than per group. For the obligation starting on 1 January 2027 the 2026 figure decides it, and that figure is known in advance.
Is a PDF invoice still allowed?
Only for as long as the issuing obligation has not reached you, and only where the recipient agrees. A plain PDF is not an e-invoice under these rules. A ZUGFeRD file is, because the structured data sits inside the document.
Do small entrepreneurs have to do anything?
They do not have to issue structured invoices, but they do have to be able to receive them, and that has applied since 1 January 2025.
Which channel does the law prescribe?
None. The German rules regulate the format, not the transport. E-mail, a portal and the Peppol network are all permissible where the recipient agrees, and that agreement is worth having in writing.
How long do invoices have to be kept?
Eight years. The structured file is the original, so keeping a PDF rendering of it is not sufficient.
Does this apply to invoices abroad?
No. The German obligation covers domestic supplies between businesses established in Germany. Cross-border invoicing follows the rules of the country concerned, which the country overview sets out.
Get ready for the German mandate
Receiving has been mandatory since January 2025, issuing follows in 2027 and 2028. Tell us where you stand and we will say what is missing and what it takes to close it.
- A reply within one business day, as a rule
- Free test account with 14 days of full access
- No ERP change, we adapt to your export
What happens next
- 01You send the form, we reply within one business day.
- 02A short call: which obligation applies to you, who your recipients are, how invoices leave your system today.
- 03Test account and a first invoice sent end to end, on your own data.
Prefer to talk directly? info@invoice-portal.de · +49 561 56014568
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