E-Invoicing in Germany: Rules and Deadlines

Since 1 January 2025, every business established in Germany must be able to receive e-invoices, freelancers and Kleinunternehmer included. Issuing them becomes mandatory for invoices to other German businesses for supplies from 1 January 2028, or from 1 January 2027 if your total turnover in the previous year was above €800,000. Kleinunternehmer (§ 19 UStG) and invoices up to €250 are permanently exempt from the issuing obligation.

If you live in Germany but don't read German tax letters for fun, this guide is for you. It also covers the case most foreigners ask about: what changes if you invoice German clients from abroad.

Need an XRechnung right now because a client or a public body asked for one? The free XRechnung generator creates an XRechnung or a ZUGFeRD PDF without an account.

What counts as an e-invoice in Germany

German law (§ 14(1) UStG) defines an e-invoice (E-Rechnung) as an invoice that is "issued, transmitted and received in a structured electronic format" that allows electronic processing. The format must follow the European standard EN 16931 or be interoperable with it.

Everything else is an "other invoice" (sonstige Rechnung): paper, but also a regular PDF, a scan, a photo or invoice details typed into an email. The Federal Ministry of Finance (BMF) explicitly lists "PDF files without embedded data" as other invoices. The PDF you send today from Word or most invoicing apps is not an e-invoice, even though it travels by email.

Two formats matter in practice:

With ZUGFeRD, the XML is what counts legally. If the PDF and the XML disagree, the BMF says the structured data prevails.

The timeline

The transition rules are in § 27(38) UStG. What matters is the date of the supply (when you did the work), not the invoice date.

Example: a web developer from Lisbon living in Berlin, registered for VAT with €70,000 turnover, bills a Munich startup €3,000 plus €570 VAT (19%). For work in November 2026, a PDF is fine. For work in March 2027, still fine, because 2026 turnover was under €800,000. For work in February 2028, it must be an e-invoice.

Receiving: what applies since 2025

Every business established in Germany must be technically able to receive e-invoices, and the BMF says this explicitly includes Kleinunternehmer. A German supplier does not need your consent to send you one.

An ordinary email inbox is enough; no separate mailbox is required. But you must be able to read the file and keep the original:

• Store the XML file (or the whole ZUGFeRD PDF) unchanged for eight years (§ 14b UStG).
• Use a viewer to make an XRechnung readable. A printout does not replace the file.
• Check the invoice details as you would on any invoice.

If you refuse an e-invoice, you have no right to demand a PDF or paper invoice instead.

Who must issue e-invoices

The obligation applies when both sides are businesses established in Germany (registered office, permanent establishment, or residence) and the work is for the client's business. It also covers self-billing (Gutschrift), domestic reverse charge under § 13b UStG, and clients who are Kleinunternehmer themselves or only make VAT-exempt sales (a landlord, for example).

It does not apply to:

• Private customers (B2C): PDF or paper remains fine. An e-invoice to a consumer requires their consent.
• Cross-border invoices: if either side is not established in Germany, there is no e-invoicing obligation. A freelancer in Madrid billing a company in Hamburg can keep sending PDFs (the client may still ask for an e-invoice by contract).
• Purely VAT-exempt services under § 4 Nos. 8–29 UStG, such as many medical treatments. If only part of the invoice is exempt, the obligation applies to the whole invoice.

Three exemptions freelancers should know

Even where the obligation applies, these invoices may always be sent as other invoices (paper or PDF):

1. Kleinunternehmer under § 19 UStG (§ 34a UStDV), also after 2028. Sending a PDF still requires the client's consent, which can be informal, for example by accepting your PDF invoices without objection.
2. Small-amount invoices up to €250 in total (§ 33 UStDV), such as a taxi receipt or an €89 spare part.
3. Tickets for passenger transport (§ 34 UStDV).

You can still send an e-invoice in these cases, and a German business client doesn't have to agree to it.

What an e-invoice must contain

The content is the same as before: the mandatory details under § 14(4) UStG, i.e. names and addresses of both parties, tax number (Steuernummer) or VAT ID, a sequential invoice number, invoice date, date of supply, quantity and description, net amount, VAT rate and VAT amount. Our guide to invoicing as a freelancer in Germany walks through each with examples.

What's new is where the details must be: in the structured part. A reference in the XML to an attached PDF that holds the description is not enough. You can still attach extras such as timesheets.

The BMF distinguishes two kinds of errors:

• Format errors: the file doesn't follow the standard. It's then not an e-invoice but an other invoice, which is a problem once the obligation applies.
• Business-rule errors: a field is missing or contradicts another. A missing buyer reference (BT-10) in an XRechnung is irrelevant for VAT purposes. A wrong VAT rate is still a content error.

Running the file through a validator helps catch both. For invoices to German public bodies, the buyer reference is usually the Leitweg-ID, without which they generally won't accept an XRechnung.

Get ready in five steps

1. Pick an inbox. Tell your suppliers which email address should receive e-invoices.
2. Sort out storage. Decide where you'll keep the original files, unchanged, for eight years.
3. Check whether you're affected. Kleinunternehmer, only private clients, only clients abroad? If you are affected: from 2027 or 2028?
4. Complete your data. A valid e-invoice needs full addresses, the client's email address, your Steuernummer or VAT ID and, for XRechnung, your phone number.
5. Test before it's mandatory. Send regular clients a ZUGFeRD invoice now and see how their bookkeeping copes.

Creating e-invoices with KipBill

For occasional invoices, the free XRechnung generator is enough: enter seller, client and lines, the form shows which required fields are still missing as you type, and you download an XRechnung 3.0 (XML) or a ZUGFeRD PDF (PDF/A-3, EN 16931 profile). It handles 19%, 7% and 0% with the Kleinunternehmer rule (§ 19 UStG) or reverse charge (§ 13b UStG). Nothing is stored and no account is needed. The tool is available in English, so you don't have to fill in German forms.

If you invoice regularly, businesses based in Germany can download any invoice in either format inside the app, from the Starter plan up. And when you email an invoice from the app, the attached PDF is already a ZUGFeRD e-invoice, as long as every line carries VAT and the data is complete. An XRechnung for a public body you upload to its portal yourself. KipBill does not send through the Peppol network.

For how other EU countries are rolling out e-invoicing, see our overview of EU e-invoicing requirements in 2026.

FAQ

Is a PDF by email still OK after 2028?

Not for invoices to other businesses in Germany, except for Kleinunternehmer, invoices up to €250 and transport tickets. For private customers and clients abroad, PDF remains allowed.

I live outside Germany and bill German companies. Does this apply to me?

No, not unless you have a registered office or permanent establishment in Germany. The obligation only applies when both sides are established in Germany. Your client may still prefer an e-invoice, and the generator can make one.

I'm a Kleinunternehmer. Do I need to do anything?

You must be able to receive and store e-invoices; an email inbox is enough. You don't have to issue them. If you switch to charging VAT, the obligation applies to you like everyone else.

Which turnover counts for the €800,000 threshold?

Total turnover under § 19(2) UStG in the previous calendar year, so for 2027 it's your 2026 turnover.

XRechnung or ZUGFeRD: which should I use?

Both are valid; you agree on the format with your client. Public bodies usually require XRechnung. Businesses without special software often find ZUGFeRD easier, because they can open the PDF as usual.

Does e-invoicing software need a certification?

No. Germany has no software certification for XRechnung or ZUGFeRD. KipBill creates files to EN 16931 and checks them in its own tests with the KoSIT validator. As with any invoice, you remain responsible for its content.

As of 20 October 2026. Sources: §§ 14 and 27(38) UStG, §§ 33 and 34a UStDV, and the BMF letters of 15 October 2024 and 15 October 2025. This article is not tax advice.