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Spotlight PEPPOL BIS Billing 3.0 The EU e-invoicing mandate is here — France Sept 2026, Belgium Jan 2026, Germany 2025.

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German reform

Germany's e-invoicing mandate: the 2025-2028 guide

Germany chose the decentralised path: no State platform, no imposed network — but a switch of the invoice format itself, already underway since January 2025 and closing in 2028.

The phased calendar

DeadlineObligationWho
1 January 2025 Mandatory reception Every VAT-registered company established in Germany, no threshold
1 January 2027 Mandatory issuance Companies with turnover > €800,000
1 January 2028 Mandatory issuance All companies; end of the bilateral EDIFACT tolerance

The German subtlety: reception is immediate and universal, but issuance stays optional until 2027-2028 — plain PDFs still circulate during the transition. The detail (BMF transitional arrangements, small amounts under §33 UStDV, B2C exclusions): the Wachstumschancengesetz, decoded.

The formats: XRechnung and ZUGFeRD

Two formats carry the reform, both compliant with EN 16931:

  • XRechnung — the German CIUS (UBL or CII), the B2G pivot format since 2020, extended to B2B.
  • ZUGFeRD — the hybrid PDF/A-3 + CII XML, cousin of Factur-X, valid from version 2.0.1 in the EN 16931 profile or higher. Beware: the MINIMUM and BASIC WL profiles do not count as invoices under §14 UStG.

Legacy EDIFACT flows remain admitted by bilateral agreement until 31 December 2027, provided EN 16931 data extraction remains possible.

The model: decentralised, no clearance

Unlike France (PDPs + a central directory) and Belgium (mandated Peppol network), Germany imposes no platform and no network: e-mail, SFTP, AS2, AS4 or API — any channel agreed between the parties is acceptable, and each company equips itself for reception. No e-reporting either at this stage: a reform is brewing for 2028+.

Getting ready: the checklist

  1. Secure reception — you must already accept EN 16931 invoices since January 2025: dedicated inbox, parsing, archiving.
  2. Choose your issuance format — ZUGFeRD for human readability, XRechnung for pure automation.
  3. Check your ZUGFeRD profiles — ban MINIMUM and BASIC WL from your B2B flows.
  4. Test compliance — the EN 16931 validator and the Factur-X/ZUGFeRD extractor run in your browser.
  5. Plan the EDIFACT exit — the bilateral agreement expires at the end of 2027: map the flows concerned.
  6. Tool up issuance before your deadline — compare the market's solutions.
  7. Track the calendar — subscribe to the alerts.

Full method: the e-invoicing go-live playbook.

Frequently asked questions

Is e-invoicing already mandatory in Germany?

For reception, yes: since 1 January 2025, every VAT-registered company established in Germany must be able to receive an EN 16931 electronic invoice, with no threshold and no exception. Issuance becomes mandatory on 1 January 2027 for companies with turnover above €800,000, then on 1 January 2028 for all.

What is the legal basis?

The Wachstumschancengesetz (Growth Opportunities Act), adopted on 27 March 2024 and published in Bundesgesetzblatt I 2024 Nr. 108, which amends §14 UStG: the EN 16931 invoice becomes the legal definition of an invoice. A BMF letter of 15 October 2024 details the transitional arrangements.

Which formats are valid?

XRechnung (the German EN 16931 CIUS, the B2G pivot format since 2020) and ZUGFeRD from version 2.0.1 in the EN 16931 profile or higher — the MINIMUM and BASIC WL profiles do not count as invoices under §14 UStG. EDIFACT remains possible by bilateral agreement until 31 December 2027, provided EN 16931 data extraction remains possible.

Is there a State platform like in France?

No. The German model is decentralised: no central platform, no imposed network. E-mail, SFTP, AS2, AS4 or API — any channel agreed between the parties is acceptable. That is the big difference with the French (PDP/PPF) and Belgian (mandated Peppol) models.

Is a plain PDF still allowed?

Only in transition: issuers can keep sending unstructured PDFs until 31 December 2026 (turnover > €800,000) or 31 December 2027 (below). Small-amount invoices (§33 UStDV) and B2C remain out of scope.

What about e-reporting?

Not yet: unlike France, Germany has not coupled its mandate with data transmission to the administration. An e-reporting reform is brewing for 2028 and beyond — the next chapter to watch.

All the Germany resources

The other deadlines