New rules for electronic invoices have applied in Germany since 1 January 2025. The key is to distinguish between receiving and issuing: businesses must already be able to receive e-invoices, while transition periods still apply to issuing them. This guide reflects the position on 14 September 2026 and distinguishes a small business from a German “Kleinunternehmer” under section 19 UStG.
1. Which invoices are covered?
The German VAT e-invoice requirement generally applies to supplies between businesses when both the supplier and the customer are established in Germany and there is a VAT obligation to issue an invoice. It therefore primarily concerns domestic B2B transactions.
Invoices to private consumers are outside this B2B requirement. If one party is not established in Germany, the domestic requirement does not automatically apply. Separate B2G rules may apply to public-sector customers.
Business size alone is not decisive. A small company may be covered, whereas a Kleinunternehmer in the specific German tax sense can use a special exception from the issuing requirement.
2. What are the deadlines for 2026, 2027 and 2028?
The timetable under section 27(38) UStG is:
- Since 1 January 2025: All domestic entrepreneurs must be able to receive e-invoices. This includes Kleinunternehmer.
- Until 31 December 2026: Every issuer may still use paper invoices for domestic B2B transactions. A simple PDF or another unstructured electronic format remains possible with the recipient’s consent.
- During 2027: The transition continues for issuers whose total turnover in the preceding calendar year did not exceed EUR 800,000. For other covered issuers, e-invoicing generally becomes mandatory.
- From 1 January 2028: Covered domestic B2B invoices must generally be issued as e-invoices. The statutory exceptions remain.
The EUR 800,000 threshold therefore only postpones the start of the issuing requirement in 2027. It is not a general threshold for having to receive e-invoices in 2025 or 2026.
3. Which exceptions matter to small businesses?
Not every invoice has to be issued as an e-invoice. Under the current rules, another form of invoice may in particular still be used for:
- supplies to private consumers,
- low-value invoices up to EUR 250 gross,
- passenger tickets that qualify as invoices,
- many VAT-exempt supplies under section 4 numbers 8 to 29 UStG,
- supplies made by Kleinunternehmer under section 19 UStG.
The Kleinunternehmer exception for issuing is set out in section 34a UStDV. Important: Kleinunternehmer have nevertheless had to be able to receive e-invoices since 2025. If they move to standard VAT taxation, the issuing requirement may also apply.
4. What is an e-invoice—and what is not?
Under section 14 UStG, an e-invoice uses a structured electronic format that enables electronic processing. Since 2025, an ordinary PDF, scan or photograph is only an “other invoice”, not an e-invoice in the statutory sense.
Common permitted formats include:
- XRechnung: a structured XML file without an embedded PDF image,
- ZUGFeRD: a readable PDF with embedded structured XML data; suitable profiles from version 2.0.1 meet the conditions, except MINIMUM and BASIC-WL,
- other agreed formats if the VAT invoice data can be extracted correctly and completely.
Technical validation is not always a prerequisite for tax recognition, but it helps identify format and content errors before sending.
5. Set up reliable receipt now
An email inbox is generally sufficient for the statutory ability to receive. In practice, the process should do more:
- Create a permanent address such as
invoice@company.de. - Inform suppliers and monitor spam and quarantine folders.
- Decide who checks, approves and posts XML files.
- Test XRechnung and ZUGFeRD with a viewer; the tax administration provides an ELSTER e-invoice viewer.
- Retain the original incoming file and link it to the order, approval and payment.
German B2B law does not prescribe one exclusive transmission channel. Email, an interface, a portal or another agreed channel may be used. There is no general requirement to obtain a formal receipt confirmation for every e-invoice.
6. Prepare issuing and master data
Even if your business still uses a transition rule in 2026, run a test. Check that your invoicing software can generate XRechnung or a suitable ZUGFeRD profile and that all mandatory details are present in the structured part. Depending on the case, these include names and addresses, tax number or VAT identification number, issue date, unique invoice number, type and date of supply, net amounts, tax rate and tax amount, or a reference to the exemption.
Also record the preferred receiving channels of business customers. A Leitweg-ID is generally not needed in ordinary B2B dealings; it is mainly relevant to invoices sent to public authorities. Test with important customers before a deadline arrives.
7. Retain invoices correctly for eight years
Invoices must be retained for eight years under section 14b UStG. The period begins at the end of the calendar year in which the invoice was issued.
For an e-invoice, at least the structured part must remain intact in its original form. An XRechnung must therefore not be retained only as an on-screen view or printed PDF. With ZUGFeRD, the embedded structured data is decisive; if the XML and visual part differ, the structured part generally prevails. Access, changes and processing steps should be organised traceably.
8. Check public-sector and cross-border cases separately
The VAT B2B requirement does not replace the rules for public-sector invoices. Federal, state and municipal customers may require portals, a Leitweg-ID, thresholds and rules specific to the relevant authority or state. Check the procurement documents and the information on E-Rechnung Bund.
Do not automatically apply the same domestic rule to cross-border supplies. Other VAT rules, special invoice details and foreign requirements may apply. Review these cases separately and obtain tax advice where needed.
9. A practical 30-day plan
- Week 1: Establish whether you use standard VAT treatment or the Kleinunternehmer scheme, which B2B transactions you have, and which deadline applies.
- Week 2: Set up the receiving inbox, responsibilities, viewer and unchanged retention of original files.
- Week 3: Clean customer and company master data and generate one XRechnung and one ZUGFeRD test file.
- Week 4: Validate the files, coordinate with the tax adviser or accounts team, and test the exchange with one supplier and one customer.
Briefly document how invoices are received, checked, corrected, approved, paid and archived. This prevents the technical process from being known by only one person.
10. Avoid common mistakes
- “We are small, so this does not affect us.” A small business is not the same as a Kleinunternehmer under section 19 UStG.
- “Our PDF is already an e-invoice.” Without structured, machine-readable invoice data, it is only another type of invoice.
- “We can wait until 2028.” Receipt has been required since 2025, and issuing can become mandatory for larger issuers in 2027.
- “Keeping the visible PDF is enough.” The structured original part must be retained.
- “XRechnung is only for authorities.” It can also be used in B2B; B2G simply brings additional requirements.
- “Software makes every invoice correct automatically.” Format checks cannot replace correct master, supply and tax data.
Motorica supports the creation of XRechnung and ZUGFeRD and the organisation of invoice data and filing. The business—and, where appropriate, its tax adviser—still remains responsible for classifying the actual transaction.
Sources and professional notice
The principal sources are the Federal Ministry of Finance e-invoice FAQ, updated March 2026, the Ministry letter of 15 October 2025, section 14 UStG, section 14b UStG, section 27 UStG and section 34a UStDV.
Current as of 14 September 2026. This article provides general information about German rules and is not tax or legal advice. Check your specific case and later legal changes with a qualified adviser or the competent authority.