E-invoicing in Germany: the E-Rechnungspflicht explained

Germany requires structured electronic invoices for domestic business-to-business supplies. Since 1 January 2025 every business established in Germany must be able to receive an e-invoice; issuing becomes mandatory on 1 January 2027 for businesses whose 2026 turnover exceeded €800,000 and on 1 January 2028 for everyone else. An e-invoice under § 14 UStG follows the European norm EN 16931 — in practice XRechnung or ZUGFeRD — and there is no central network: e-mail is enough.

What counts as an e-invoice under § 14 UStG?

An e-invoice (elektronische Rechnung) is an invoice issued, transmitted and received in a structured electronic format that allows electronic processing. Everything else — paper, plain PDF, scans — is a "sonstige Rechnung" (other invoice). The definition comes from the Wachstumschancengesetz of 27 March 2024 and applies since 1 January 2025.

§ 14 Abs. 1 Satz 6 UStG accepts two kinds of structured format:

1. a format that conforms to the European norm for electronic invoicing (EN 16931) and its syntax list under Directive 2014/55/EU — this covers XRechnung and the EN 16931-conformant profiles of ZUGFeRD;
2. a format agreed between the parties (for example EDI), provided the UStG data can be extracted correctly and completely into an EN 16931-conformant or interoperable format.

A PDF showing an invoice is not an e-invoice, even when e-mailed. A hybrid ZUGFeRD file is, because the structured XML inside the PDF is the legally decisive part. See structured invoice vs PDF and EN 16931.

Who is obliged, and from when?

The obligation applies to supplies between businesses that are both established in Germany (§ 14 Abs. 2 Satz 2 Nr. 1 UStG). It applies to receiving since 2025 and to issuing in stages set out in § 27 Abs. 38 UStG.

The obligation is tied to the supply date, and the €800,000 test uses the turnover of the calendar year before the supply. Which date applies to a particular business requires professional confirmation.

The rule also covers self-billing credit notes (Gutschrift), domestic reverse-charge supplies (§ 13b UStG), flat-rate farming, travel and margin-scheme supplies, and applies even when the recipient is a Kleinunternehmer.

Which invoices are excluded?

Four groups may always be issued as "sonstige Rechnung" — paper or, with consent, PDF — even after 2028:

• Small-amount invoices with a gross total not exceeding €250 (§ 33 UStDV);
• Tickets for passenger transport used as invoices (§ 34 UStDV);
• Invoices of Kleinunternehmer under § 19 UStG (§ 34a UStDV) — they remain obliged to receive e-invoices;
• Supplies exempt under § 4 Nr. 8 to 29 UStG (for example most financial, insurance, medical and educational services and the letting of property), for which there is no duty to invoice at all.

Invoices to consumers and to or from businesses established abroad are outside the obligation. In every excluded case the issuer may still send an e-invoice, which the recipient must accept.

Which formats satisfy the obligation?

Any EN 16931-conformant format is permitted. Two dominate in Germany, both accepted by the tax administration (UStAE 14.1 Abs. 13 and 14):

The choice between them is practical; XRechnung vs ZUGFeRD walks through it. European formats are compared at e-invoice formats.

How are e-invoices transmitted? Is there a central platform?

No. Germany prescribes no transmission channel, no clearance and no real-time reporting for B2B invoices. The BMF confirms that an e-mail inbox is sufficient, that no dedicated inbox is required, and that download portals or interfaces are equally acceptable; Peppol is optional. This differs from Poland (KSeF) and France (approved platforms); see Peppol vs national networks. The receiving side does the technical work — opening, validating and archiving the XML — described at receiving e-invoices in Germany.

B2G: invoicing public authorities

Invoices to the federal administration have had to be electronic since 27 November 2020 for direct awards from €1,000 net (E-Rechnungsverordnung). Since September 2025 the Bund receives them through one platform, the OZG-RE, into which the former ZRE was merged; channels are web entry, upload, e-mail and Peppol. It expects XRechnung or another EN 16931-conformant format and routes each invoice by the Leitweg-ID in the buyer reference field (BT-10). The Länder run their own portals under their own regulations; follow the buyer's instructions. See B2B vs B2G.

What the BMF letters add

The BMF letter of 15 October 2024 (BStBl I S. 1320), amended by the letter of 15 October 2025 and written into the Umsatzsteuer-Anwendungserlass, settles the practical points:

• Format errors vs business-rule errors (Rn. 6a, 6b). A file that violates the syntax is not an e-invoice at all but an "other invoice". A file that violates EN 16931 or XRechnung business rules is still an e-invoice; only errors in the VAT mandatory content (§§ 14 Abs. 4, 14a UStG) make it incorrect. A missing buyer reference is irrelevant for VAT.
• Validation (Rn. 35a). Validation supports but does not replace the recipient's check. A business observing ordinary commercial care may rely on a suitable validator's result; keeping the report is recommended.
• Hybrid files (UStAE 14c.1 Abs. 4a). A PDF part that deviates from the XML may count as a second invoice under § 14c; input VAT is deductible only from the structured part.
• Retention (Rn. 60). Eight years (§ 14b UStG); at least the structured part must be kept unchanged in its original form.
• Input VAT (UStAE 15.2a). Where an e-invoice is mandatory, an "other invoice" is not a proper invoice and does not in principle support input VAT deduction — unless the supplier corrects it or the recipient proves by objective evidence that the substantive conditions are met, which a content-correct "other invoice" will regularly do (Abs. 1a). Individual cases require professional confirmation.

How KRONENWERK handles this

SUPPORTED KRONENWERK generates XRechnung and ZUGFeRD at issuance and validates every file before release against the EN 16931 rules and the KoSIT Schematron, cross-checked with the Mustang library; a file that fails a rule is not issued. The tax verdict per invoice (standard, reverse charge, exempt, outside scope, or "requires professional confirmation") is derived from the transaction's facts, and the buyer's VAT ID is checked against VIES. Incoming XRechnung and ZUGFeRD files are read into bills with the original XML kept unchanged. The free e-invoice checker validates a file without storing it. Because Germany prescribes no network, e-mail delivery is sufficient. Details: e-invoicing product page and Germany country page.