Phased Implementation Timeline (2025–2028)
Germany is headed towards a phased structured e‑invoicing mandatory regime for domestic B2B transactions in the period 2025 to 2028. There will be complete conformance to the European EN 16931 standard. This road map sets out the key milestones and technical structure covered under the Growth Opportunities Act with the objective of making business processes simpler and enhancing VAT controls.
Mandatory E-Invoicing Timeline
January 1, 2025: E-Invoice Reception Becomes Mandatory
- All German-based companies must be able to accept electronically formatted invoices in accordance with EN 16931.
- These are XRechnung, Peppol BIS, and later versions of ZUGFeRD (2.3 or newer).
- While email reception remains acceptable, organizations are urged to utilize formalized, automated channels (e.g., Peppol) for greater reliability.
- Key to this is that the EN 16931-approved e-invoice then becomes the legal default—companies cannot decline an e-invoice nor request paper/PDF alternatives.
January 1, 2027: Mandatory Issuance for Large Businesses
- Companies with an annual turnover exceeding €800,000 in the previous year will be required to issue structured e-invoices.
- PDFs, paper invoices, or non-EN 16931-compliant EDI formats will no longer be permitted, even with the buyer's consent.
January 1, 2028: Universal Mandate
- Every other German company has to send EN 16931-compliant e-invoices.
- Legacy EDI type non-conformant formats are not acceptable anymore.
- This third stage is the complete embracing of online invoicing by the German economy.
Accepted E-Invoicing Formats
- EN 16931 is the official European standard that defines the required structure and data for e-invoices, ensuring cross-border system interoperability.
- Accepted formats include:
- XRechnung – The German standard and a core part of public sector compliance.
- Peppol BIS – Widely used in EU cross-border invoicing.
- ZUGFeRD 2.3 or higher – A hybrid format combining a human-readable PDF with embedded XML data.
- Older or unstructured formats (e.g., PDFs, paper) will gradually become non-compliant under the new rules.
Exemptions for Small Businesses
Firms that fall under the Kleinunternehmerregelung (Small Business Scheme) are exempt from providing EN-compliant invoices. However:
- They ought to be capable of receiving EN 16931-conformant invoices.
- Turnover thresholds have been updated:
- Previous fiscal year: Up to €25,000
- Current fiscal year: Up to €100,000
Practical & Technical Considerations
Email vs. Peppol
- Initially, email remains an acceptable method of receiving structured invoices (as XML attachments).
- However, secure networks like Peppol are strongly recommended to enable automation and reliability.
Electronic Cash Register Reporting
- Since July 1, 2025, companies are required to register their electronic cash register systems (TSEs) with the tax office.
- Systems acquired before this date must be reported by July 31, 2025.
- Systems acquired after must be registered within one month of purchase.
Archiving Requirements
- The invoice retention time will be shortened from 10 to 8 years as of January 1, 2025.
- The 10-year retention rule still applies to other papers, such as books and accounting records.
Regional Implementation – The Bavarian Example
- On January 7, 2025, Bavaria announced a centralized invoicing portal based on the OZG-RE platform.
- This platform supports:
- Web capture
- File upload
- Email
- Peppol-based transmission
- Rollout is expected during the first half of 2025 and may serve as a model for other federal states.
Enforcement & Refusals
- Details on enforcement mechanisms are still evolving.
- If a recipient refuses to accept an e-invoice, the supplier’s VAT obligation is still considered fulfilled.
- The recipient has no legal right to demand an alternative invoice format.
Conclusion
Germany's planned e-invoicing mandate is a significant step towards full digitalization of B2B invoicing and VAT declarations. Starting from January 1, 2025, all businesses must be able to receive EN 16931-compliant e-invoices, the beginning of a systematic and standardized invoicing era. Issuance obligations will be in place for larger companies from 2027, with the mandate spreading to all companies by 2028. To remain competitive, businesses must actively adopt compliant formats such as XRechnung, Peppol BIS, or new iterations of ZUGFeRD, and adopt automated platforms such as the Peppol network for secure and efficient invoice exchange. Even smaller companies that are exempted from sending out structured e-invoices should still be capable of receiving them. Since the legislation and technology are still in doubt, particularly regarding enforcement and electronic reporting, it is crucial that all companies keep themselves up to date, review internal procedures, and invest in systems that enable the long-term shift towards electronic invoicing.