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Germany E-Invoicing: XRechnung, ZUGFeRD, and the B2B Mandate Explained

Since January 2025 every German business must be able to receive structured e-invoices, with sending obligations phasing in through 2028. Here's how XRechnung and ZUGFeRD differ, the full timeline, and what to do now.

Invocie Team · 2026년 5월 18일 · 7 분 분량

Germany is the EU's largest economy and, as of 2025, one of its most consequential e-invoicing markets. The Growth Opportunities Act (Wachstumschancengesetz) redefined what a legal invoice is: from 1 January 2025, a structured electronic invoice is the default for domestic business-to-business transactions, and a paper or PDF invoice is now, in the law's language, an 'other invoice.' If you sell to German businesses, this affects you whether or not you are based in Germany.

Is e-invoicing mandatory in Germany?

Yes — but the obligation arrived in two halves. Since 1 January 2025, every domestic B2B business in Germany must be able to RECEIVE a structured e-invoice; there is no transition period and no turnover threshold for receiving. The obligation to SEND structured e-invoices phases in later. Until then, you may still send paper or PDF invoices only with the recipient's consent, and only during the transition window.

The German e-invoicing timeline: 2025 to 2028

  • 1 January 2025: All domestic B2B businesses must be able to receive EN 16931-conformant e-invoices. Receiving is mandatory immediately, for everyone.
  • Through 31 December 2026: Senders may still issue paper or PDF invoices with buyer consent (a transition allowance). EDI formats remain usable if they can carry EN 16931-compliant data.
  • 1 January 2027: Businesses with prior-year turnover above €800,000 must SEND structured e-invoices. Smaller senders keep the PDF option one more year.
  • 1 January 2028: All remaining businesses must send structured e-invoices. The PDF-with-consent allowance ends for everyone.

XRechnung vs ZUGFeRD: which format should you use?

Both conform to EN 16931, so both are legally valid for B2B. The practical difference is the counterparty. XRechnung is XML-only and is required for most business-to-government (B2G) invoicing in Germany, so if you invoice public authorities you need it. ZUGFeRD's embedded-PDF design is friendlier for B2B partners who still want a human-readable document alongside the structured data — the PDF opens like any invoice, and the XML is extracted by systems that support it. Many German businesses standardize on ZUGFeRD for B2B and XRechnung for B2G, and a good platform emits either from the same underlying invoice.

There is no clearance portal — for now

Unlike Italy's SDI or the clearance models of Saudi Arabia and Mexico, Germany's 2025 mandate has no central government platform through which invoices must pass. Invoices are exchanged directly between the parties (by email, EDI, a portal, or a Peppol Access Point). A continuous transaction control / real-time reporting layer is expected later this decade, aligned with the EU's VAT in the Digital Age (ViDA) framework, but the current obligation is about format and exchange, not clearance. Building on EN 16931 and Peppol today means you are ready for that reporting layer when it lands.

What German businesses (and their suppliers) must do

  1. Enable receiving immediately. This is already law. At minimum you need an inbox and a system that can parse and archive EN 16931 XML — a plain PDF workflow no longer satisfies the receiving obligation.
  2. Pick your outbound format. Decide between XRechnung and ZUGFeRD by counterparty type: XRechnung for public-sector buyers, ZUGFeRD for B2B partners who want the hybrid PDF. A platform that emits both removes the choice as a constraint.
  3. Make your ERP produce EN 16931 XML. Your billing system must output structured, validation-clean data — correct VAT categories (UNCL5305), BT-fields populated, and totals that reconcile per rate.
  4. Confirm archiving compliance. German GoBD rules require the structured original to be archived, not just a PDF rendering. Store the XML as the system of record.
  5. Plan for the 2027 sending deadline now. If your turnover is above €800,000, your sending obligation is closer than it looks. Pilot outbound e-invoicing with a real partner well before the cutover.

Invocie's EUStrategy emits EN 16931-conformant output — XRechnung, ZUGFeRD, and Peppol BIS Billing 3.0 — from a single canonical invoice, so a finance team selling into Germany, Italy, and the wider EU integrates once. The same canonical invoice also clears ZATCA Phase-2 in Saudi Arabia and UAE PINT in the Emirates, which is how a multi-country seller avoids one integration per mandate.

Frequently asked questions

Is e-invoicing mandatory in Germany?
Yes. Since 1 January 2025, every domestic B2B business in Germany must be able to receive structured e-invoices that conform to EN 16931 — there is no transition period or turnover threshold for receiving. The obligation to send structured e-invoices phases in from 2027 (for businesses above €800,000 turnover) and 2028 (for everyone else).
What is the difference between XRechnung and ZUGFeRD?
XRechnung is a pure-XML invoice format (a German CIUS of EN 16931) mainly used for business-to-government invoicing. ZUGFeRD is a hybrid format: a human-readable PDF/A-3 with a machine-readable XML invoice embedded inside it. Both conform to EN 16931 and both are legally valid for B2B from the correct profile — ZUGFeRD from version 2.0.1 (Comfort/EN 16931 profile) onward.
When does Germany's e-invoicing mandate start?
The receiving obligation started on 1 January 2025 for all domestic B2B businesses. Sending becomes mandatory on 1 January 2027 for businesses with prior-year turnover above €800,000, and on 1 January 2028 for all remaining businesses. Until those dates, paper or PDF invoices may be sent only with the recipient's consent.
Is a PDF invoice still valid in Germany?
Only during the transition and only with the recipient's consent. Since January 2025 a plain PDF is legally an 'other invoice,' not a structured e-invoice, and it no longer satisfies the receiving obligation. From 2028 the PDF-with-consent allowance ends entirely and structured e-invoices become mandatory for sending.
Does Germany use a government clearance portal for e-invoicing?
No. Unlike Italy's SDI or the clearance models of Saudi Arabia and Mexico, Germany's 2025 mandate has no central platform through which invoices must pass. Invoices are exchanged directly between the parties. A real-time reporting layer is expected later this decade, aligned with the EU's VAT in the Digital Age (ViDA) framework.
Do foreign businesses selling to Germany need to comply?
If you issue domestic B2B invoices to German-established businesses, the format rules apply to those transactions. In practice, any supplier that invoices German business customers should be able to send EN 16931-conformant XRechnung or ZUGFeRD, and every German customer must already be able to receive structured e-invoices as of January 2025.

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