Germany B2B E-Invoicing: The New Standard for Business Transactions
Germany’s B2B e-invoicing framework is a structured invoicing system introduced to improve fiscal transparency, reduce administrative burdens, and align with EU standards for electronic invoicing in domestic business transactions.
Preparing your SAP Landscape for Germany’s Digital Invoice Mandate
key implementation dates
Keep track of key dates and einvoicing mandates in Germany
01/01/2025
Starting from January 1, 2025, all businesses in Germany must be able to receive structured electronic invoices in compliance with the EN 16931 standard.
01/01/2027
Starting from January 1, 2027, companies with an annual turnover exceeding €800,000 will be required to issue e-invoices for domestic B2B transactions
01/01/2028
Starting from January 1, 2028, electronic invoicing will become mandatory for all businesses, regardless of size or revenue.
Overview of Germany’s B2B E-Invoicing Requirements
Implementation
Issuance becomes mandatory in 2027 for companies over €800,000 turnover and in 2028 for all businesses
Tax Authority
Federal Central Tax Office (Bundeszentralamt für Steuern – BZSt)
Format
EN 16931-compliant formats, including XRechnung and ZUGFeRD/Factur-X. ZUGFeRD 2.5 adds updated code lists and support for gross invoicing
Digital Signature
Not required under current legislation for domestic B2B invoices
Archiving
Invoices must be stored electronically for 10 years in an audit-proof format
Other German regulations
Is your SAP system ready for Germany’s mandatory B2B e-invoicing and XRechnung standards?
Frequently asked questions
Will PDF invoices still be accepted after 2028?
No. From 2028, only structured e-invoices, such as XRechnung or ZUGFeRD/Factur-X-compliant formats, will be accepted for domestic B2B transactions. Standard PDF invoices will no longer be considered valid for tax purposes.
Hybrid formats such as ZUGFeRD combine a human-readable PDF/A-3 file with embedded EN 16931-compliant XML. The ZUGFeRD 2.5 update does not change this architecture, but improves alignment with current EN 16931 code lists and adds support for gross invoicing scenarios.
Do I need to send my e-invoices to a government platform like in other EU countries?
No. Unlike systems like KSeF in Poland or RO e-Factura in Romania, Germany does not use a centralized government platform. E-invoices are exchanged directly between businesses or through service providers or Peppol.
What happens if my customer can’t receive e-invoices yet?
From 2025 onward, all businesses are expected to be able to receive structured e-invoices. If your customer is not prepared, it may result in non-compliance on their part—not yours.
Will cross-border invoices be affected by this regulation?
No, the current e-invoicing mandate in Germany applies only to domestic B2B transactions. Cross-border invoices are not yet subject to this obligation.
Can I still use my current invoicing software?
Currently, the requirement only applies to receiving electronic invoices — issuing them will not be mandatory until 2027. Companies can continue using their existing ERP or billing systems, provided they are adapted to comply with legal requirements, such as receiving invoices in EN 16931-compliant XML format (e.g., XRechnung). Most systems will need updates or plugins to support this functionality.
Is Peppol mandatory in Germany?
No, Peppol is not mandatory in Germany, but it is widely used by many businesses and public entities for secure and standardized e-invoice exchange.
How mandatory e-invoicing and the Growth Opportunities Act will impact business in Germany
The introduction of mandatory B2B e-invoicing in Germany represents a significant shift for VAT-registered companies operating in the domestic market. Following the Growth Opportunities Act (Wachstumschancengesetz), businesses are required to receive and, increasingly, issue structured electronic invoices compliant with the European EN 16931 standard, such as XRechnung or ZUGFeRD formats. This means that ERP systems must be capable of generating, validating, and transmitting compliant invoice data, while ensuring seamless archiving and interoperability across the German business ecosystem in a fully automated and secure way.
At Code10, we support this transition through a combination of SAP Standard implementation and advance eCompliance integration delivered via our eCompliance Hub. We maximize SAP’s native functionalities wherever applicable and develop targeted enhancements when regulatory or technical requirements go beyond standards capabilities. Our approach ensures structured invoice generation, format validation, and secure transmission through Peppol and other certified networks, enabling organizations to meet German B2B obligations efficiently and with full technical reliability.
