Phasing in · DE
E-invoicing in Germany.
Receiving mandatory since January 2025; issuing phases in through 2027 and 2028.
The calendar
| Date | Who | What becomes mandatory |
|---|---|---|
| 2019-11-01 | Public sector entities | Receiving and processing structured invoices compliant with EN 16931. |
| 2025-01-01 | Every business | Being able to RECEIVE an EN 16931 invoice. This half has no turnover threshold. |
| 2027-01-01 | Businesses above EUR 800,000 turnover | Issuing: paper and unstructured electronic formats stop being allowed. |
| 2028-01-01 | Every remaining business | Issuing, with no threshold left. |
Verified on 2026-08-17 against European Commission, eInvoicing in Germany. Mandate calendars move, and several of these have moved once already. If you are reading this well after that date, check the source before acting on it, and tell us if it has changed.
How invoices actually move
Decentralised, and deliberately so. There is no single national clearing platform for B2B. Public bodies receive through ZRE and OZG-RE with a Leitweg-ID for routing, and Peppol transmission is supported by federal and national authorities.
What the document has to be
XRechnung, a pure XML file, and ZUGFeRD 2.1, a PDF with the XML embedded. Peppol BIS Billing 3.0 is also supported. All three are ways of satisfying EN 16931.
What most summaries get wrong
- The asymmetry is the whole thing, and it is the part most summaries bury. Receiving has been mandatory for every business since January 2025 with no threshold; issuing is what phases in over 2027 and 2028. A company that reads only the 2027 headline concludes it has two years to do nothing and is already non-compliant.
- ZUGFeRD is a hybrid: a human-readable PDF carrying structured XML inside it. It counts as an electronic invoice. A plain PDF does not, whatever it looks like.
- Paper and non-compliant EDI remain permissible where the buyer consents, until the issuing deadlines close that door.
Where we fit
InvoiceForge builds and checks the document: it generates an EN 16931 invoice, validates one against the rules a real validator reports, and reads one back into structured data. An agent can call it directly.
It does not transmit. Reaching Germany means going through the network above, and that is a separate piece we would rather name than blur. You need both, and knowing which one you are missing is worth more than a page that implies one product does everything.
We are not affiliated with the European Commission, OpenPeppol, or any tax authority. The dates on this page come from the Commission's own country factsheets and, where one exists, the national portal linked above.