E-invoices in Germany: who must send them, from when, and what counts.

Since 1 January 2025 every business in Germany, freelancers and small businesses included, must be able to receive e-invoices (E-Rechnung); an email inbox is enough. Sending them to other German businesses becomes compulsory in two steps: from 1 January 2027 if your turnover in 2026 was over 800,000 euros, and from 1 January 2028 for everyone else. An e-invoice is a structured data file, such as XRechnung or ZUGFeRD; a PDF is not one. Invoices to private customers or to clients abroad, invoices up to 250 euros and invoices under the small-business rule never have to be e-invoices.

1. What counts as an e-invoice

Since 2025 the VAT Act (Umsatzsteuergesetz, UStG) splits invoices into two kinds (§ 14(1) UStG):

• an e-invoice (elektronische Rechnung) is issued, sent and received in a structured electronic format that software can process. The format has to follow the European standard EN 16931, or be one both sides agree on, as long as all required details can be extracted into that standard without loss;
• every other invoice is a "sonstige Rechnung": paper, a PDF, a scan, a photo, or an invoice typed into an email.

The formats used in Germany that qualify, according to the Federal Ministry of Finance (Bundesministerium der Finanzen, BMF):

Two consequences. In a ZUGFeRD file, the XML is the invoice: if the PDF and the data disagree, the data counts. And every required invoice detail must be in the structured part. Extras, such as a time sheet, can travel as a PDF attachment inside the e-invoice, but a link to a download page doesn't count as part of the invoice.

What has to be on the invoice doesn't change. Our guide to invoice requirements lists the details; an e-invoice carries the same ones as data.

2. Receiving: required since 2025

Every business based in Germany has had to be able to receive e-invoices since 1 January 2025. There are no exceptions: it covers freelancers, small businesses under the small-business rule (Kleinunternehmerregelung) and landlords who only make VAT-exempt sales. A supplier sending you an e-invoice doesn't need your consent.

The bar is low. The BMF says an email inbox is enough, and it doesn't have to be a separate one. What you do need is a way to:

• read the file. An XRechnung is code to the human eye. The tax administration's free viewer at e-rechnung.elster.de displays XRechnung and ZUGFeRD files, and many accounting programs do it too;
• keep it: the structured file, unchanged, for eight years. A printout or a PDF rendering doesn't replace it.

A business that can't or won't accept an e-invoice has no right to demand paper instead. If the sender can show it tried to deliver the e-invoice properly, for example with a sending log, it has done its part.

3. Sending: the 2027 and 2028 dates

The obligation to send e-invoices applies when both you and your client are based in Germany and the client buys for its business (§ 14(2) UStG). The transition rules are in § 27(38) UStG:

The threshold is your total turnover (Gesamtumsatz) in the previous calendar year, as defined for the small-business rule: the sum of your taxable sales, counted when paid, with some exempt sales and sales of the business's own fixed assets left out (§ 19(2) UStG). It's turnover, not profit. A designer with 120,000 euros of 2026 turnover, for example, can send PDFs with the client's agreement through 2027, and sends e-invoices for work done from 1 January 2028.

The year-end trap. The law ties the transition rules to when the work was done and to when the invoice is sent. Work done in December 2026 but invoiced in January 2027 falls outside the wording of both rules. Reports say the BMF takes the more generous view in an unpublished letter (the date of the work counts), but commentators disagree, so the question is open. Invoicing 2026 work before the year ends avoids it.

Advance and instalment invoices issued before your own start date don't have to be e-invoices, even if the work and the payment come later (BMF letter of 15 October 2026).

4. What never has to be an e-invoice

The e-invoice obligation only applies where an invoice is required in the first place, and only between businesses in Germany. So it doesn't cover:

• private customers (B2C). An e-invoice to them needs their consent;
• clients based abroad, in the EU or outside it. Invoices to them can stay on paper or, with their agreement, PDF;
• sales that are VAT-exempt under § 4 Nr. 8 to 29 UStG, such as most medical treatment, residential letting and financial services;
• invoices up to 250 euros including VAT (§ 33 UStDV);
• invoices under the small-business rule (§ 34a UStDV). A small business may still send e-invoices, without the client's consent. If it moves to normal VAT, the obligation applies from then on. Our guide to the small-business rule covers the thresholds;
• tickets for passenger transport that count as invoices (§ 34 UStDV);
• sales to legal entities that aren't businesses, such as many associations, and certain property-related work for private clients.

The exceptions only cover sending. A small business or a doctor still has to be able to receive e-invoices from suppliers. Cash payment makes no difference: once the transition ends, a restaurant bill over 250 euros for a business meal is covered like any other invoice.

Invoices to public authorities follow separate rules. Federal bodies have required e-invoices from suppliers since 27 November 2020 under the E-Rechnungsverordnung (ERechV), for invoices from 1,000 euros and through the federal invoice portal. Where both sets of rules apply, the stricter one decides.

5. What freelancers need in practice

For most freelancers and small companies the change is less dramatic than it sounds, because the obligation to send starts in 2028 for anyone under 800,000 euros. What usually needs sorting before then:

• An address for incoming e-invoices. Some suppliers already send XRechnung or ZUGFeRD files. Telling them which address to use keeps the files out of personal inboxes.
• Storage that keeps the original file. Eight years, unchanged (§ 14b UStG). For VAT, storing e-invoices outside an archive system that meets the rules for digital records (GoBD) is not a breach in itself, but those rules still apply for other tax purposes.
• Invoicing software that can produce XRechnung or ZUGFeRD and check the file (validation). Many invoicing and accounting programs already do; the BMF names none and recommends validating before sending. The public-sector standards The public coordination office for IT standards (KoSIT) publishes a free open-source validator, and the BMF suggests keeping the validation report as evidence.
• A word with regular clients. Which format and which route (email, portal, interface) is a contract question between the two of you. For the VAT rules, any EN 16931 format is fine, and a client can't insist on paper once e-invoices are compulsory.
• The link to your bookkeeping. If a Steuerberater or a bookkeeping program processes your receipts, agree how e-invoices get there with the data intact.

Nothing stops you from sending e-invoices to German business clients before your date: that has been allowed without the client's consent since 2025.

6. Mistakes and what follows from them

• A PDF where an e-invoice is required isn't a proper invoice. The client then generally can't deduct the VAT from it, and can demand a correct one. The BMF has said this alone is not an administrative offence (letter of 15 October 2026). Not issuing a required invoice at all, or issuing it more than six months late, can be fined up to 5,000 euros (§ 26a UStG).
• A broken file (format error: it doesn't match the syntax) isn't an e-invoice, just a sonstige Rechnung in another electronic format.
• A file that fails a validation rule (business-rule error) is still an e-invoice for VAT purposes. It matters only if the error hits a required invoice detail, such as a VAT amount that doesn't match the rate. An empty "buyer reference" field, which German business clients don't need, doesn't matter for VAT.
• Corrections have to be e-invoices too, once the original had to be one, and must refer clearly to the original invoice.

While the transition rules let a supplier send a PDF, that PDF still counts as a proper invoice for the client's input tax.

7. The three BMF letters

The law sets the frame; the BMF's letters (BMF-Schreiben) set out how the tax offices apply it. They bind the tax administration, not the courts.

• 15 October 2024 (BStBl I p. 1320): the basic rules. Definitions, allowed formats, the receiving duty, the transition, and the effect on input tax.
• 15 October 2025 (BStBl I p. 1806): format errors versus business-rule errors, all required details in the structured part, attachments for time sheets, keeping the structured file, and the matching changes to the administration's VAT guidelines (Umsatzsteuer-Anwendungserlass).
• 15 October 2026 (BMF letter): advance and final invoices, how detailed the description of the work must be, construction invoices, discounts, invoices priced gross, corrections, the consequences of a business-rule error, fee notices from public bodies, and no fine for sending a sonstige Rechnung instead of an e-invoice. E-invoices issued by the end of 2026 that follow the earlier letters are accepted even if they miss the new points.

The BMF's own questions and answers on the e-invoice (in German) are the clearest short summary.

8. What comes next

The e-invoice is the groundwork for a reporting system: the government plans to have certain invoice data sent to the tax administration close to the time of each transaction. The BMF says the government will propose the legal changes "in due course", and that the current e-invoice rules may be adjusted for it. No bill had been published by October 2026.

At EU level, the "VAT in the Digital Age" package adopted on 11 March 2025 makes e-invoices and near real-time reporting compulsory for business sales between EU countries from 1 July 2030 (European Commission). Until then, invoices to EU clients aren't part of the German e-invoice obligation.

9. Where it gets complicated

For a freelancer with German business clients, the steps above are mostly administrative. The questions worth a closer look:

• turnover near 800,000 euros, and which sales count towards it;
• work done in December 2026 and invoiced in January 2027;
• a mix of clients: German businesses, private customers, clients abroad;
• VAT-exempt sales next to taxable ones, or a move out of the small-business rule;
• advance, instalment and final invoices on long projects;
• connecting invoicing, storage and bookkeeping so nothing gets lost.

A Steuerberater can check how the rules apply to your clients and set up the handover of e-invoices to your bookkeeping.

Your e-invoice checklist