Mandatory e-invoicing in Germany 2025, 2027, 2028: who must do what, and when?

What is an e-invoice?

An e-invoice (E-Rechnung) is an invoice in a structured, machine-readable format according to the European standard EN 16931. A PDF, a photo or a Word document does not count. Two formats are mainly used:

• XRechnung: a pure XML file, required for invoices to public authorities (with a Leitweg-ID).
• ZUGFeRD (version 2.0.1 or later, EN 16931 profile or higher): a PDF with embedded XML. People read the PDF, accounting software reads the XML.

The deadlines

• Since 1 January 2025: all businesses must be able to receive e-invoices. An email inbox is enough.
• Until 31 December 2026: paper and PDF invoices are still allowed (PDF only with the client's consent).
• From 1 January 2027: businesses with more than €800,000 turnover in the previous year must issue e-invoices.
• From 1 January 2028: all businesses must issue e-invoices for B2B sales.

Who is exempt?

• invoices to private individuals (B2C)
• Kleinunternehmer under § 19 UStG, when issuing
• small invoices up to €250 gross
• travel tickets

What does this mean for freelancers and small businesses?

If your turnover in the previous year was €800,000 or less, you may keep sending PDF invoices until the end of 2027, as long as your client agrees. Many business clients are already switching their accounting and ask for e-invoices. Switching early gets you paid faster.

E-invoicing with Rechnaro

Rechnaro creates ZUGFeRD invoices in the EN 16931 profile (PDF/A-3 with embedded XML), right in your browser. That covers the requirement for business clients.

For public authorities and companies that ask for XRechnung, Rechnaro also creates an XRechnung 3.0 file (XML, checked with the official KoSIT validator). Enter the Leitweg-ID in the “Leitweg-ID / reference” field. You upload the file to the invoice portal yourself, for example ZRE or OZG-RE; Rechnaro does not send it automatically via Peppol.