E-Invoice Mandate in Germany
The Growth Opportunities Act introduces mandatory e-invoicing for B2B transactions in phases. Learn what this means for your business and how to prepare.
Timeline: When Does It Apply?
The e-invoice mandate is being introduced in stages. The key milestones:
January 1, 2025 — Receiving mandate
From January 1, 2025, all businesses based in Germany must be able to receive e-invoices. This means you need a technical solution to accept and process structured electronic invoices in XRechnung or ZUGFeRD format.
This mandate is already in effect — regardless of company size or industry.
January 1, 2027 — Sending mandate (large businesses)
Businesses with prior-year revenue exceeding 800,000 euros must send e-invoices to other businesses. Paper invoices and simple PDF invoices will no longer be permitted for B2B transactions.
January 1, 2028 — Sending mandate (all businesses)
The obligation to send e-invoices applies to all businesses regardless of revenue. From this date, every B2B invoice in Germany must be transmitted as a structured electronic invoice per EN 16931.
Who Is Affected?
The e-invoice mandate covers all B2B transactions (business-to-business) within Germany. Specifically:
- All businesses based in Germany that invoice other businesses
- Freelancers and self-employed individuals invoicing businesses
- Foreign businesses with tax registration in Germany
Exemptions:
- Invoices to private individuals (B2C)
- Small-amount invoices under 250 euros (transitional provision)
- Transport tickets and certain tax-exempt services
What Formats Are Accepted?
The law requires e-invoices to comply with the European norm EN 16931. The following formats meet this requirement:
XRechnung (UBL)
XML-based format using Universal Business Language. Standard for the public sector and fully EN 16931 compliant.
XRechnung (CII)
XML-based format using Cross Industry Invoice. Technically equivalent to UBL, commonly used in international contexts.
ZUGFeRD (Comfort profile and above)
Hybrid format combining PDF and embedded XML. From the Comfort profile onwards, ZUGFeRD is EN 16931 compliant and accepted for the e-invoice mandate.
Simple PDF invoices, scanned invoices, and image-format invoices do not qualify as e-invoices under the law.
How to Prepare Your Business
Transitioning to e-invoices doesn't have to be complicated. Follow these steps:
1. Ensure receiving capability
Make sure you can receive and process e-invoices. With Rekivo, you get a dedicated email address where business partners can send their e-invoices.
2. Set up validation
Not every e-invoice is correct. Validate incoming invoices automatically against EN 16931 to catch errors early.
3. Adapt your processes
Integrate e-invoice processing into your existing accounting and approval workflows. Rekivo offers workflows and export functions for this.
4. Prepare for sending
Get ready for the sending mandate: check whether your accounting software can create e-invoices in XRechnung or ZUGFeRD format.