E-invoicing: An overview and the reforms due to come into force on 1 January 2025 and 1 January 2027/1 January 2028
New rules for business-to-business invoices have been in force since 2025. This overview explains the topic in just a few minutes and directs you to the relevant in-depth articles.
Introduction
Since 1 January 2025, electronic invoicing (e-invoicing) has been enshrined in law as the standard method for sending invoices in business transactions between domestic companies. This means there will be a number of changes for you when receiving and sending invoices. We’ll guide you through this transition and take care of the tax-related aspects – this overview shows what to expect and where you can find more detailed information.
First, a few clarifications, as there are often misunderstandings surrounding e-invoices: an invoice sent as a PDF via email is no longer considered an e-invoice from 2025 onwards, but rather an ‘other invoice’. A genuine e-invoice is a structured data set that software can automatically read – a mere image of an invoice does not qualify.
This article serves as an introduction. From here, the topics branch out into separate articles – covering everything from incoming and outgoing invoices to formats and specific sectors.
What has changed since 2025
Under the Growth Opportunities Act, the legislator has stipulated that invoices between domestic companies are to be gradually converted to a structured electronic format. The rationale is that structured invoice data can be processed automatically without anyone having to retype it.
The transition is taking place in two phases, which differ in terms of timing:
The receipt of e-invoices has been mandatory for all businesses since 2025, with no transition period. If a supplier sends you an e-invoice in one of the permitted e-invoice formats (e.g. XRechnung, ZUGFeRD), you must be able to accept this invoice. This obligation applies to all businesses, including small businesses.
Staggered transition periods up to 2028 apply to the issuing of e-invoices. These do not affect every business owner. However, the implications are significant in this respect: anyone who is obliged to issue e-invoices but fails to do so runs the risk that customers will no longer pay their invoices on time. Furthermore, from 1 January 2027/1 January 2028 (depending on the case), only e-invoices will qualify for input tax deduction.
At our firm, we are making all the necessary preparations to ensure that the structured data is fed directly into your accounts. What you need to do depends on whether you only receive invoices or also issue them yourself.
Incoming invoices: Receiving e-invoices
Receiving e-invoices is the most urgent matter, as the obligation applies immediately. You must be able to accept e-invoices, make them legible, check them and retain them for ten years.
To receive e-invoices, all you need is an email inbox – an expensive portal is not required. The following articles explain how to open, check, archive incoming e-invoices in accordance with GoBD and forward them to us:
Even if you do not issue e-invoices yourself, you must be able to receive them. From 2025, a business partner may send you an e-invoice without asking first – and you cannot refuse to accept it.
Outgoing invoices: creating and sending e-invoices
If you issue invoices to other businesses (B2B), the requirements for sending them also apply to you – though with transition periods. Until your respective deadline, you may still use paper or PDF invoices with the recipient’s consent.
The mandatory details on an invoice remain the same; only the format changes. You can read here what you need to bear in mind when creating, sending, correcting and making advance payments:
The formats: XRechnung and ZUGFeRD
A valid e-invoice must be in a structured format in accordance with the European standard EN 16931. In Germany, two formats are particularly common: XRechnung (a pure XML file, often used for invoices to public authorities) and ZUGFeRD (a PDF with embedded structured data).
You do not need to be familiar with both formats. When receiving e-invoices, it is your software that processes the format anyway; when sending them, one format that suits your recipients is usually sufficient. We explain the differences and how to choose the right format separately:
Who is affected – and who isn’t
In principle, all domestic businesses trading with other businesses are affected. Exceptions include, amongst others, invoices to private individuals, small-value invoices up to €250 and certain tax-exempt transactions.
A common special case involves small business owners under Section 19 of the German Value Added Tax Act (UStG): they will still not be required to issue e-invoices in future, but must be able to receive them. This article explains who is subject to the obligation and in what capacity:
Which tool you use
The practical steps you’ll need to take depend on your software. Some programmes create, receive and archive e-invoices in full; others – such as pure payment services or till systems – only cover parts of the process and require additional software.
There are separate step-by-step guides for the most common programmes. Which ones are visible to you depends on which tools are used in your organisation. Please contact us if your programme is not listed – we’ll then show you the right way forward.
Special cases and sectors
Certain scenarios generate the most queries in practice – such as hospitality receipts, small amounts, recurring payments or sector-specific issues in the skilled trades, healthcare professions, clubs and the letting sector. We cover these in separate articles as soon as they are relevant to your situation:
How we work together
The tasks are clearly divided – you are responsible for ensuring technical readiness to receive e-invoices, whilst we handle the tax processing.
Your responsibilities:
- Be able to receive e-invoices (at least one email inbox)
- Forward incoming e-invoices to us, in their original format and not as printouts
- If you issue your own invoices, select the appropriate format as your deadline approaches
Our responsibilities:
- To inform you of your specific deadline and what action you need to take
- Set up the data transfer to us (e.g. via DATEV Unternehmen Online)
- Post the structured data and analyse it for tax purposes
We’ll tailor this breakdown to your software and processes during our discussion.
Frequently asked questions
Is a PDF invoice an e-invoice?
No. Since 2025, a standard PDF – even if sent by email – has been classified as an ‘other invoice’, not an e-invoice. An e-invoice contains structured, machine-readable data – either as pure XML (XRechnung) or as a PDF with embedded data (ZUGFeRD).
Do I have to start sending e-invoices now?
You have been required to receive them since 2025. Transition periods apply to sending them: depending on your turnover, you may continue to use paper or PDF until the end of 2026 or the end of 2027, provided the recipient agrees. From 2028 at the latest, sending e-invoices will be mandatory when doing business with other businesses.
I’m a small business owner – does this affect me at all?
To some extent. As a small business owner, you are not permanently required to issue e-invoices. However, you must receive them from 2025 onwards, just like any other business.
Do I need expensive software or a portal for this?
An email inbox is sufficient simply for receiving invoices. Whether it’s worth investing in invoicing software depends on whether and how many invoices you issue yourself. We can advise you on this on a case-by-case basis.
What happens to my old paper invoices?
Invoices that you received or issued before the changeover remain valid and should be kept as before. The new rules apply to transactions from 2025 onwards.
Do I now have to report invoices to the tax office in real time?
No. There is currently no obligation to report invoices automatically to the tax authorities. Such a reporting system is planned at EU level, but the details are still to be finalised in Germany – this should be kept separate from the current e-invoicing requirement.
How do my e-invoices reach you?
Via the channels agreed with us, usually via DATEV Unternehmen online or a dedicated upload address. The key point is that we receive the original file, not a printout. We’ll sort out the details during set-up.
Legal notice
This article provides an overview and does not replace individual advice. The legal situation and its interpretation may change; the current status at any given time is decisive. The specific deadlines and actions required in your case depend on your individual circumstances.
If you have any questions about your transition, please contact us directly.
As at: June 2026