Mandatory E-invoicing in Germany: 2025 Dates and Details Explained
Digital invoicing is rapidly becoming a standard in the European Union, with mandatory adoption in many regions to promote efficiency, transparency, and tax compliance. Germany is embracing this transformation by moving away from traditional paper and PDF invoices to fully digital, structured e-invoices. The upcoming mandate outlines specific requirements and deadlines that businesses must meet to ensure uninterrupted operations.
Continue reading to explore Germany's e-invoicing regulations, their impact on businesses, and the critical deadlines you need to know.
What are the new e-invoicing regulations in Germany?
Definition of a German e-invoice
Under the new mandate, an electronic invoice is defined as an invoice transmitted and received in a structured electronic format. Unlike the older standard, where PDFs were considered electronic invoices, the updated definition requires invoices to be machine-readable, typically in XML format. This ensures automated processing and compliance with the European standard EN 16931.
Machine readability is ensured when structured XML data takes precedence in the event of discrepancies between the human-readable and machine-readable portions of the invoice. This requirement is fulfilled by the structured data format (XRechnung), which can also appear in a hybrid format, such as ZUGFeRD and PDF containing embedded XML data.
Key deadlines and requirements for e-invoicing in Germany
Soft start: January 1, 2025
From this date, all businesses in Germany must be ready to receive e-invoices. Businesses can no longer reject electronic invoices if sent in the correct format. While this phase is primarily about readiness to receive invoices, businesses are encouraged to communicate with suppliers and service providers to ensure seamless adaptation.
Mandatory implementation: January 1, 2027
Starting in 2027, all B2B invoices issued in Germany by companies with annual revenues exceeding EUR 800,000 must comply with mandatory electronic formats, as specified by the new regulatory framework. This includes:
- Replacing paper and PDF invoices with structured electronic formats.
- Ensuring systems are capable of generating and processing e-invoices.
Exemptions
- Very small businesses (with turnover below a certain threshold) may have additional time to adapt.
- The mandate does not currently apply to B2C transactions or invoices involving specific sectors, such as banking or insurance.
Three ways that the German mandate impacts businesses
1. Transition challenges
- Businesses must upgrade their systems to issue and process structured e-invoices.
- Collaboration with suppliers, customers, and service providers is critical to ensure compatibility.
2. Process automation
- The mandate emphasizes digital transformation, allowing businesses to benefit from faster processing, reduced errors, and cost savings.
3. Exceptions and special cases
- Cross-border transactions will follow separate EU harmonized reporting requirements, expected to be introduced in the near future.
- Businesses using older, non-standard formats may face compliance challenges.
Three best practices for e-invoicing compliance in Germany
1. Assess current systems
- Evaluate whether your existing invoicing software supports structured formats such as XRechnung or ZUGFeRD.
2. Engage service providers
- Collaborate with your service provider to implement systems that can generate and receive e-invoices, or consider finding a new provider.
3. Prepare for future changes
- Although Germany's initial implementation does not include real-time reporting, future EU regulations, such as ViDA, may necessitate additional adjustments.
Stay ahead of Germany’s e-invoicing mandates
The introduction of e-invoicing in Germany is a pivotal moment in digital transformation for businesses. With phased implementation and a clear timeline, your organization has a window of opportunity to adapt its processes and systems to the new requirements. Proactive preparation will ensure compliance and deliver you the benefits of streamlined operations and reduced administrative burdens.
With Comarch’s full coverage of B2G compliance at the Federal State level and innovative solutions such as ”Comarch E-mail Converter”, we’re ready to tackle the challenges of 2025 and beyond. As a proud member of the German Institute for Digitalization in Tax Law (IDST) Association, we ensure your business stays compliant and future-ready. Contact us today to discover how Comarch can simplify your compliance journey!
