E-Invoicing in Germany: What Businesses Need to Know (2025–2028)

Germany is moving business-to-business invoicing to structured electronic invoices in stages between 2025 and 2028. If you run a company in Germany, or sell to German business customers from abroad, this guide explains what changes, when, and what it means for how you store your invoices.

The timeline

The rules come from the German Growth Opportunities Act (Wachstumschancengesetz), which amended section 14 of the German VAT Act. They apply to invoices between businesses that are both established in Germany.

From	What applies
1 January 2025	Every business must be able to receive e-invoices. An email inbox is enough.
until 31 December 2026	Businesses may still send paper invoices, and PDF invoices if the recipient agrees.
1 January 2027	Businesses with a prior-year turnover above €800,000 must send e-invoices.
until 31 December 2027	Smaller businesses may still send paper and PDF invoices.
1 January 2028	All businesses must send e-invoices for domestic B2B sales.

Exceptions include invoices of up to €250 (small-amount invoices), travel tickets, invoices to consumers (B2C), and certain VAT-exempt supplies. Small businesses under the German small-business VAT scheme (Kleinunternehmer, section 19 of the VAT Act) don’t have to send e-invoices, but must be able to receive them.

What counts as an e-invoice?

An e-invoice is structured data that software can process without retyping. It must follow the European standard EN 16931. A PDF, a photo or a scan is not an e-invoice, even if it arrives by email.

	XRechnung	ZUGFeRD
Format	a pure XML file	a PDF/A-3 file with embedded XML
Readable by people?	only with a viewer	yes, like any PDF
Typical use	invoices to public authorities, increasingly B2B	B2B, especially smaller companies
Valid e-invoice?	yes	yes, from version 2.0.1, except the MINIMUM and BASIC WL profiles

ZUGFeRD is the same format as the French–German Factur-X, which makes it a practical choice if you invoice customers in both countries.

What it means for companies outside Germany

The obligation to send e-invoices applies when both the supplier and the customer are established in Germany. A company without a registered office, place of management or fixed establishment in Germany is generally not covered, even if it is registered for VAT there.

In practice, this matters anyway:

• German customers’ accounting systems are being built around e-invoices. Sending ZUGFeRD or XRechnung makes you easier to pay.
• If you have a German subsidiary or branch, it is fully covered by the mandate.
• Other EU countries are introducing their own mandates on different timelines, and EU-wide digital reporting (ViDA) is coming. Choosing EN 16931-compatible software now saves you a second switch later.

Archiving e-invoices in Germany

Getting the invoice is half the job; keeping it correctly is the other half. German rules require:

• Eight years of retention for invoices (shortened from ten years in 2025).
• The original format. For an XRechnung that’s the XML file; for ZUGFeRD it’s the PDF with the embedded XML. A printout or a rendered image doesn’t count.
• Unaltered and machine-readable storage, so a tax auditor can evaluate the data.
• Traceability: who received, checked and booked the invoice, and when.

These requirements are part of GoBD, Germany’s rules for electronic bookkeeping and archiving. See What is GoBD? and why GoBD matters for companies outside Germany.

Checklist

1. Set up one dedicated email address for incoming invoices and give it to your suppliers.
2. Check that your accounting software or accountant can read XRechnung and ZUGFeRD.
3. Check that your invoicing software can create them, and plan the switch before 2027 or 2028.
4. Make sure your archive keeps the original file unaltered, not just a PDF copy.
5. Document how invoices arrive, are checked and archived.

Archiving e-invoices with Papermerge

Here’s what Papermerge does today, and what it doesn’t yet:

• ZUGFeRD and Factur-X invoices are archived like any PDF: Papermerge keeps the file unaltered, including the embedded XML, and protects it with a checksum.
• By email: forward invoices to the email address of a cabinet. The email is kept as an .eml file and each attachment as its own document in its original form.
• Pure XRechnung XML files can’t be uploaded yet, and Papermerge doesn’t read invoice data from the XML. Support is planned; we’ll update this guide when it ships.

Invoice number, supplier, date and amount are captured as metadata of your Incoming invoice category, and the eight-year retention period runs automatically.