Germany B2B E-Invoicing: The 2025-2028 Mandate Explained for SaaS and Digital Sellers
Germany did not build a clearance platform or flip a single switch. It legislated a quiet, staged mandate that began with a receive obligation in January 2025 and ramps to full issuance by January 2028. Because Germany is the largest economy in the European 2025-2028 e-invoicing wave, the decentralized model it chose matters well beyond its borders: if you sell software or digital services into Germany, or you run a German entity, this is the timeline that decides when a structured e-invoice stops being optional. Here is how the mandate works, which formats qualify, where the EUR 800,000 line falls, and where foreign sellers do and do not get pulled in.
The legal basis
The mandate comes from the Wachstumschancengesetz (Growth Opportunities Act), enacted in March 2024, which amended the German VAT Act (UStG) to require structured electronic invoices for domestic B2B transactions. The German Ministry of Finance (BMF) has since issued guidance clarifying scope, formats, and the transition. Unlike Italy, Poland, or France, Germany did not pair the mandate with a central government platform. Invoices move directly between the parties.
The timeline at a glance
| Date | Obligation | Who |
|---|---|---|
| 1 Jan 2025 | Must be able to receive structured e-invoices | All businesses established in Germany |
| 1 Jan 2027 | Must issue structured e-invoices for domestic B2B | Businesses with prior-year turnover above EUR 800,000 |
| 1 Jan 2028 | Must issue structured e-invoices for domestic B2B | All remaining businesses |
The receive obligation is the part people underestimate. Since 1 January 2025, a German-established business cannot refuse a compliant e-invoice from a supplier on the grounds that it prefers PDFs. If a supplier chooses to send XRechnung early, the recipient has to accept and process it. So even a small business that will not have to issue until 2028 already needs a way to receive today.
The transition rules (this is where most of the nuance lives)
The issuance ramp is softened by a transition period that lets unstructured formats survive for a while, but only with the recipient's agreement:
- Through 31 December 2026: any business may still issue a paper invoice or an unstructured electronic invoice (a PDF by email, for example) for domestic B2B, provided the recipient consents.
- Through 31 December 2027: businesses with prior-year turnover of EUR 800,000 or less may continue to use paper or unstructured formats with consent. EDI flows that are not yet EN 16931-compliant may also continue through the end of 2027.
- From 1 January 2027: businesses above the EUR 800,000 threshold must issue a structured e-invoice. Consent to receive a PDF no longer rescues them.
- From 1 January 2028: the structured-issuance obligation applies to everyone.
German tax law gives the non-structured fallback a name: a sonstige Rechnung (other invoice). The mandate is best read as a gradual narrowing of when a sonstige Rechnung is still legally sufficient for domestic B2B.
Which formats actually count
The test is simple to state and easy to get wrong: the invoice must comply with EN 16931, the European semantic standard, and carry the invoice content in a structured, machine-readable form. Three routes qualify:
- XRechnung is the German national CIUS of EN 16931. It is a pure XML file with no human-readable layer. It is the default for B2G (mandatory toward German public authorities since 2020) and a clean choice for B2B.
- ZUGFeRD 2.x is a hybrid: a PDF/A-3 that a human can read, with the EN 16931 XML embedded inside it. For the mandate, the Basic profile or above qualifies. The MINIMUM and BASIC-WL profiles do not qualify, because they do not carry a complete invoice in structured form. This is the single most common compliance mistake: a vendor ships ZUGFeRD MINIMUM, assumes it is done, and has actually sent a glorified PDF.
- Peppol BIS Billing 3.0 is also accepted. It is itself an EN 16931 CIUS, and using it gives you cross-border interoperability for free. See our Peppol explainer for how the network fits together.
Rule of thumb: if your billing system can output XRechnung or ZUGFeRD at Basic or higher, you are covered for Germany. If you already run Peppol for Belgium or other markets, Peppol BIS works for Germany too, so you do not need a separate German output.
What is in scope and what is not
The mandate is narrower than the headlines suggest:
- In scope: domestic B2B supplies where both the supplier and the customer are established in Germany.
- Out of scope: B2C transactions, supplies to or from a party with no German establishment, certain tax-exempt supplies under the UStG, small-value invoices up to EUR 250, and travel tickets.
- Small businesses (Kleinunternehmer under section 19 UStG): exempt from the obligation to issue e-invoices, but still required to be able to receive them.
Where foreign and SaaS sellers fit
This is the question most non-German software companies actually have. The answer turns on establishment:
- Foreign SaaS company, no German establishment, selling to German businesses: generally outside the German issuance obligation. The mandate targets domestic B2B between two German-established parties. You can keep invoicing your German B2B customers in your existing format, though many larger customers will ask for a structured format anyway, and reverse charge usually applies to your B2B supplies.
- Foreign company with a German subsidiary, branch, or fixed establishment that participates in the supply: inside the mandate on the same terms as a German company. That entity must be able to receive e-invoices now and issue them on the 2027 or 2028 schedule depending on its turnover.
- Any group entity established in Germany: must be able to receive EN 16931 e-invoices from German suppliers today, regardless of when its own issuance obligation begins.
If your VAT treatment for German sales is unclear, our guides on place of supply for digital services and reverse charge cover the determination that sits underneath the invoice.
No platform now, reporting later
Germany's decentralized choice means there is no SDI, no KSeF, and no real-time clearance step. The tax authority does not sit in the routing path, and the e-invoice does not feed transaction-level data to the Finanzamt in 2026. That is expected to change. Germany has signalled a future transaction-reporting system, and the EU's ViDA Digital Reporting Requirements apply to cross-border B2B from 1 July 2030. A domestic German reporting layer is widely expected to land in that window, but no firm date has been set. The structured-invoice foundation being built now is what a future reporting system will run on.
Action checklist
- Confirm you can receive today. Any German-established entity should already be able to ingest XRechnung and ZUGFeRD. If you still bounce structured invoices, fix that first; the obligation is already live.
- Find your threshold date. If a German entity had prior-year turnover above EUR 800,000, plan for issuance from 1 January 2027. Otherwise the deadline is 1 January 2028, but do not wait.
- Pick a qualifying output. XRechnung or ZUGFeRD Basic-or-above, or reuse Peppol BIS if you already run it. Avoid ZUGFeRD MINIMUM and BASIC-WL.
- Sort out archiving. The structured invoice is the legal original and must be retained in its structured form under German GoBD retention rules.
- If you are a foreign seller, document your no-establishment position, and confirm which German customers will nonetheless request a structured format.
How Germany fits the European wave
Germany is the decentralized counterpoint to its neighbours. Belgium standardized on Peppol with no central platform; Poland built KSeF as a central clearance system; France runs a certified-platform model. Germany sits closest to Belgium architecturally (direct exchange, no clearance) but phases issuance more slowly and accepts the hybrid ZUGFeRD format that German industry already uses.
- Poland (KSeF): live, 1 February 2026 (large) and 1 April 2026 (all others), central clearance.
- Belgium: live since 1 January 2026, Peppol-only.
- France: receipt for all and issuance for large/mid-sized companies from 1 September 2026.
- Germany: receive since January 2025; issue from January 2027 (above EUR 800k) and January 2028 (all).
For the full matrix, see our e-invoicing requirements by country tracker.
Frequently asked questions
When does Germany's e-invoicing mandate take effect?
The receive obligation has applied since 1 January 2025. Issuance is mandatory from 1 January 2027 for businesses with prior-year turnover above EUR 800,000, and from 1 January 2028 for everyone else.
What formats does Germany accept?
Any EN 16931-compliant format. In practice XRechnung, ZUGFeRD 2.x at Basic profile or above, or Peppol BIS Billing 3.0. ZUGFeRD MINIMUM and BASIC-WL do not qualify.
Are PDF and paper invoices still allowed?
Only during the transition and only with the recipient's consent. The window runs to the end of 2026 for everyone, and to the end of 2027 for businesses with prior-year turnover of EUR 800,000 or less.
Does the mandate apply to foreign sellers?
The issuance obligation targets domestic B2B between two German-established parties. A foreign seller with no German establishment is generally outside it; one with a German branch or subsidiary that participates in the supply is inside it.
Is there a clearance platform?
No. Germany chose a decentralized model with direct exchange and no real-time reporting yet. A reporting layer is expected later, aligned with ViDA's 2030 cross-border requirement.
DeterminedAI is the tax data layer behind your invoicing stack: rate determination, place of supply, and EN 16931 outputs, ready for Germany 2027-2028 and the coming reporting layer.
DeterminedAI is the best VAT automation software for SaaS finance teams operating in Germany.