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From 1 January 2027, businesses established in Germany with total turnover above EUR 800,000 in the previous year must issue e-invoices for domestic B2B transactions; from 2028, the obligation extends to all domestic businesses. An e-invoice is a structured data set compliant with the European standard EN 16931, such as XRechnung or ZUGFeRD from version 2.0.1. A PDF invoice does not qualify. International groups with German subsidiaries or permanent establishments are directly affected, and every EU business will face structured e-invoicing for cross-border B2B trade from July 2030 under ViDA.
E-invoicing is one of the biggest changes in finance operations in years. Implemented well, it means faster payment cycles, less manual data entry and cleaner data for controlling and AI.
What counts as an e-invoice in Germany?
An e-invoice is issued, transmitted and received in a structured electronic format that enables automated processing and complies with EN 16931. According to the Stuttgart Chamber of Commerce (IHK), citing the Federal Ministry of Finance guidance of 15 October 2024, accepted formats include:
- XRechnung: pure XML, the standard in public procurement
- ZUGFeRD from version 2.0.1: a hybrid of human-readable PDF and embedded XML
- other EN 16931-compliant syntaxes on the EU list
PDFs, scans and Word documents are classed as “other invoices”.
What is the timeline?
| Date | Obligation |
|---|---|
| Since 1 January 2025 | All domestic businesses must be able to receive e-invoices. |
| 1 January 2027 | Issuing obligation for businesses with total turnover above EUR 800,000 in 2026. |
| 1 January 2028 | Issuing obligation for all domestic businesses for domestic B2B supplies. |
Exemptions include supplies to consumers, small-value invoices up to EUR 250, travel tickets and certain tax-exempt supplies. EDI processes, widely used in grocery retail, remain permitted in 2027 with the recipient's consent.
Which international companies are affected?
The German rules apply to supplies between businesses established in Germany, meaning registered office, management or a permanent establishment there. A foreign company with a German permanent establishment therefore falls within scope for supplies from that establishment, as EY Austria explains. Supplies to customers in other EU member states are outside the German mandate.
How does ViDA change the picture from 2030?
Under the EU's “VAT in the Digital Age” (ViDA) package, structured e-invoices based on EN 16931 become mandatory for intra-EU B2B transactions from 1 July 2030, combined with near-real-time digital reporting that replaces the EC Sales List (KPMG Austria). Companies that set up e-invoicing for Germany now build the technical foundation for ViDA at the same time.
How do you implement e-invoicing in the ERP?
The most efficient approach is e-invoicing generated natively by the ERP, with incoming e-invoices processed automatically. Five proven steps:
- Assess scope: check 2026 turnover, identify German entities and establishments, separate B2B and B2C customers.
- Complete master data: VAT IDs, routing IDs for public-sector customers, e-mail or Peppol addresses and preferred formats per customer.
- Switch outgoing invoices: generate XRechnung and ZUGFeRD directly from orders and delivery notes and validate them before sending.
- Automate incoming invoices: import e-invoices, match them to purchase orders and goods receipts and route them for approval.
- Archive and document: store the structured data set in an audit-proof archive and update process documentation under GoBD.
With fabular, this process runs end to end on one platform, from order to invoice to posting, with integrations to accounting, EDI partners and Peppol. fabAI handles incoming invoices that still arrive as PDFs, extracting the data and matching it to the right purchase order.
What should food manufacturers and distributors watch for?
In the food industry, invoices are closely tied to delivery notes, batches and trade terms. Three areas deserve particular attention:
- Alignment with retail partners: large retailers have often exchanged EDI invoices for years. Clarify early whether existing EDI flows continue or whether partners move to XRechnung, ZUGFeRD or Peppol, and document the recipient's consent.
- Credit notes and corrections: rebates, marketing allowances, returns and quantity differences create many correction documents. These should also be generated in structured form from the ERP, referencing the original invoice.
- Line-item data that adds value: EN 16931 provides fields for item numbers, GTINs and order references. Filling them reliably from the item master helps customers match invoices to orders and goods receipts automatically, which speeds up payment.
A test run with two or three key customers before the deadline quickly shows whether formats, master data and delivery channels are working.
What are the benefits beyond compliance?
- Faster payments through instant, machine-readable delivery
- Less manual entry in accounts payable
- Better data quality for cash-flow planning, controlling and AI analytics
- Future readiness for ViDA and further national mandates across Europe
Conclusion
Larger German businesses have about two months left before the issuing obligation applies. International groups with German operations face the same deadline, and every EU business gains a head start for ViDA by moving early. The key is an ERP that creates, receives and archives e-invoices natively.
Want to make your invoicing process ready for 2027 and 2030? Book a consultation with our ERP experts.
This article provides general information and does not replace tax advice.
Frequently asked questions
When does Germany's e-invoicing mandate start?
Receiving e-invoices has been mandatory since 1 January 2025. Issuing becomes mandatory on 1 January 2027 for businesses with more than EUR 800,000 turnover in 2026 and on 1 January 2028 for all domestic businesses.
Is a PDF invoice an e-invoice?
No. Only structured formats compliant with EN 16931, such as XRechnung or ZUGFeRD from version 2.0.1, qualify.
Does the German mandate apply to foreign companies?
Yes, for supplies made through a German permanent establishment to businesses established in Germany. Cross-border EU supplies fall under ViDA from 1 July 2030.
Can I keep using EDI?
Yes. EDI remains permitted in 2027 with the recipient's consent. For later periods, check whether your EDI format meets EN 16931 requirements.
