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German E-Invoicing (E-Rechnung)

Dernière mise à jour : 2026-03-06

Sources:bundesfinanzministerium.de

E-Invoicing in Germany (DE)

This article provides an overview of the mandatory electronic invoicing (E-Rechnung) regulations in Germany, based on information from the Bundesministerium der Finanzen (BMF) (Federal Ministry of Finance).

Current Status

As of January 1, 2025, the use of electronic invoices (E-Rechnungen) is generally mandatory for transactions between domestic businesses (B2B-Umsätze) in Germany, for services performed after December 31, 2024. This is a result of the Wachstumschancengesetz (Growth Opportunities Act) which revised the invoicing rules under § 14 Umsatzsteuergesetz (UStG) (Value Added Tax Act) [BMF FAQ, Introduction].

An E-Rechnung is defined as a structured electronic format that is issued, transmitted, and received, and enables electronic processing. A simple PDF document, for example, no longer qualifies as an E-Rechnung because it lacks a structured format. Invoices that do not meet these criteria are considered "sonstige Rechnungen" (other invoices), including paper invoices or unstructured electronic formats like PDFs [BMF FAQ, Q2].

Private end-consumers (B2C-Umsätze) are not affected by these regulations [BMF FAQ, Introduction, Q4].

Timeline

  • January 1, 2025: The obligation to use E-Rechnungen for B2B transactions between domestic businesses officially begins for services performed after December 31, 2024. From this date, all domestic businesses must be able to receive E-Rechnungen [BMF FAQ, Introduction, Q12].
  • January 1, 2025 – December 31, 2026: A transition period applies. During this time, invoice issuers can choose to issue a "sonstige Rechnung" (other invoice) instead of an E-Rechnung. This includes paper invoices or other electronic formats (e.g., PDF via email), provided the recipient agrees to the electronic format [BMF FAQ, Q11].
  • Until December 31, 2027: This transition period is extended for invoice issuers whose total turnover in the previous calendar year did not exceed 800,000 Euro. These businesses can continue to issue "sonstige Rechnungen" until the end of 2027 [BMF FAQ, Q11].
  • Until December 31, 2027: Electronic Data Interchange (EDI) procedures that do not yet meet the requirements of an E-Rechnung can still be used [BMF FAQ, Q11].
  • After these transition periods: The use of E-Rechnungen will be fully mandatory for all B2B transactions between domestic businesses [BMF FAQ, Q11].

Formats Accepted

An E-Rechnung must comply with the European standard series EN 16931, which specifies a structured, XML-based format that allows for automatic electronic processing of invoice content [BMF FAQ, Q7].

Specifically, the following formats are considered compliant with the Umsatzsteuergesetz (UStG) requirements for an E-Rechnung in Germany:

  • XRechnung [BMF FAQ, Q7]
  • ZUGFeRD from version 2.0.1 (excluding the MINIMUM and BASIC-WL profiles) [BMF FAQ, Q7]

Other formats can be agreed upon between the invoice issuer and recipient, provided that the chosen format allows for the correct and complete extraction of all information required by the UStG. This means that existing EDI procedures, such as those using EDIFACT, can continue to be used if they meet these criteria [BMF FAQ, Q7].

Exemptions

The obligation to issue an E-Rechnung does not apply in the following cases [BMF FAQ, Q4]:

  • Invoices to private end-consumers (B2C-Umsätze).
  • Many tax-exempt turnovers as per § 4 Number 8 to 29 UStG (e.g., tax-exempt financial services, tax-exempt property rentals).
  • Invoices for small amounts (Kleinbeträge) up to 250 Euro gross amount (§ 33 Umsatzsteuer-Durchführungsverordnung (UStDV)) (VAT Implementation Regulation).
  • Tickets (Fahrausweise) that serve as invoices (§ 34 UStDV).
  • Services provided by small businesses (Kleinunternehmer) as per § 34a UStDV. (Note: While Kleinunternehmer are exempt from issuing E-Rechnungen, they are still required to be able to receive them [BMF FAQ, Q12]).
  • Services to legal entities that are not businesses (e.g., many associations/Vereine not acting entrepreneurially, or state institutions).
  • Certain services to end-consumers related to real estate.

Furthermore, foreign businesses that are registered for Umsatzsteuer (USt) (VAT) in Germany but do not have a fixed establishment here can indicate this on their invoice as a reason for not issuing an E-Rechnung [BMF FAQ, Q3].

During the transition periods (see "Timeline" above), businesses can also temporarily be exempt from issuing E-Rechnungen [BMF FAQ, Q11].

Technical Requirements

Definition and Content

An E-Rechnung must be in a structured electronic format that enables electronic processing. All mandatory information required by the UStG must be contained within the structured part of the E-Rechnung. A mere reference in the structured data to an unstructured attachment (e.g., a PDF) containing mandatory invoice details is not sufficient for complete electronic processing. However, supplementary information can be included in an attachment [BMF FAQ, Q7a].

Transmission Channels

The law does not prescribe a specific method for transmitting E-Rechnungen, allowing for flexibility. Possible transmission methods include [BMF FAQ, Q8]:

  • Email
  • Electronic interface
  • Shared central storage (e.g., within a corporate group)
  • Physical transfer (e.g., via USB stick)
  • Download from an internet portal

The specific transmission method in a given case is a civil law matter to be agreed upon by the contracting parties [BMF FAQ, Q8].

Reception Capability

From January 1, 2025, all domestic businesses must be able to receive E-Rechnungen. An email inbox is considered sufficient for this purpose [BMF FAQ, Q8, Q12].

Leitweg-ID

A Leitweg-ID (routing ID) is generally not required for E-Rechnungen exchanged between businesses (B2B-Bereich). It is only necessary when sending an E-Rechnung to a public authority (B2G-Bereich) to enable clear electronic addressing. If a format requires an entry in the "BT-10 (Buyer reference)" field, a placeholder (e.g., "-") is sufficient for B2B invoices [BMF FAQ, Q6].

Visualization

For received E-Rechnungen, especially those in XML-only formats like XRechnung, businesses will need software (viewers) to display them in a human-readable format. For hybrid formats like ZUGFeRD, the structured XML part is now the authoritative part, meaning that if there's a discrepancy between the electronic data and the visual image, the structured data takes precedence. The Finanzverwaltung (tax authorities) provides an E-Rechnungsviewer via the ELSTER portal (www.e-rechnung.elster.de) for XRechnung and ZUGFeRD formats [BMF FAQ, Q12a].

Storage

E-Rechnungen must be stored for eight years, in accordance with § 14b Absatz 1 UStG. At a minimum, the structured part of the E-Rechnung must be stored intact in its original form. Storage and archiving of E-Rechnungen outside of a GoBD-compliant (Grundsätze zur ordnungsmäßigen Führung und Aufbewahrung von Büchern, Aufzeichnungen und Unterlagen in elektronischer Form sowie zum Datenzugriff) (Principles for the proper keeping and storage of books, records and documents in electronic form as well as for data access) data processing system does not automatically constitute a violation of § 14b Absatz 1 UStG [BMF FAQ, Q13].

Practical Impact for Freelancers and Small Businesses

Mandatory Reception

From January 1, 2025, all domestic businesses, including freelancers (Freiberufler) and small businesses (Kleinunternehmer), must be equipped to receive E-Rechnungen. A standard email inbox is sufficient for this requirement [BMF FAQ, Q3, Q12].

Mandatory Issuance (with Transition Periods)

While the general obligation to issue E-Rechnungen for B2B transactions begins on January 1, 2025, significant transition periods apply, which are particularly relevant for freelancers and small businesses:

  • General Transition: Until December 31, 2026, you can still issue "sonstige Rechnungen" (e.g., paper invoices or PDFs via email, with recipient consent) instead of E-Rechnungen [BMF FAQ, Q11].
  • Extended Transition for Smaller Businesses: If your total turnover in the previous calendar year was up to 800,000 Euro, you can continue to issue "sonstige Rechnungen" until December 31, 2027 [BMF FAQ, Q11]. This extended period provides more time for many freelancers and small businesses to adapt.

Exemptions from Issuance

  • Kleinunternehmer (small businesses using the small business regulation) are exempt from the obligation to issue E-Rechnungen, though they must still be able to receive them [BMF FAQ, Q4, Q12]. If a Kleinunternehmer switches to regular taxation, the E-Rechnung obligation applies from that point [BMF FAQ, Q4].
  • Invoices for small amounts (up to 250 Euro gross) are also exempt from the E-Rechnung requirement [BMF FAQ, Q4].

Software and Process Adaptation

  • Invoicing Software: Businesses will need to ensure their invoicing software can generate E-Rechnungen in accepted formats like XRechnung or ZUGFeRD (version 2.0.1 or higher). This enables the required structured electronic processing [BMF FAQ, Q7].
  • Receiving and Processing: While you are not obligated to perform extensive electronic processing beyond storage, using E-Rechnungen can simplify accounting processes by avoiding duplicate data entry and reducing errors [BMF FAQ, Q1, Q9]. Tools for visualizing XML-based E-Rechnungen (like the ELSTER viewer) will be necessary [BMF FAQ, Q12a].
  • Cash Purchases: For B2B cash purchases exceeding 250 Euro, an E-Rechnung is required if the transition periods are not utilized. It is possible to initially issue a paper receipt and then correct it with an E-Rechnung sent via email later [BMF FAQ, Q10].

Business-to-Government (B2G) Invoicing

If you invoice public authorities, separate regulations under the E-Rechnungsverordnung des Bundes (ERechV) (Federal E-Invoicing Ordinance) apply. These rules, which have been in effect since November 27, 2020, are independent of the UStG requirements and must be observed concurrently. They may have different thresholds (e.g., from 1,000 Euro) and require specific transmission channels (e.g., OZG-RE) and a Leitweg-ID [BMF FAQ, Q4a, Q6]. More information is available at www.e-rechnung-bund.de [BMF FAQ, Q4a].

Further Information

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