E-invoicing in Germany, 2025 to 2028, plainly explained

Germany is moving business invoices from paper and PDF to structured e-invoices. The rules arrive in three steps between 2025 and 2028, and most of what is written about them is either too technical or too alarming.

I worked on this topic closely while designing WirFaktura, an e-invoicing product for freelancers and small businesses. This is the plain version I wish I had found at the start. It is not tax advice. For your own situation, your tax advisor has the final word.

What an e-invoice actually is

An e-invoice is not a PDF sent by email. A PDF is a picture of an invoice: a person can read it, but software cannot reliably understand it.

An e-invoice is a structured data record. The amount, the tax rate, the due date and the description of the service sit in named fields that software can read, check and book without anyone typing them in again. In Germany it has to follow the European standard EN 16931.

In practice there are two common formats. XRechnung is pure structured data. ZUGFeRD combines a readable PDF with the structured data embedded inside it. Both meet the standard.

Step one: since 2025, everyone has to be able to receive

Since 1 January 2025, every business in Germany has to be able to receive e-invoices from other businesses in Germany. You do not have to send them yet, but when a supplier sends you one, you need a way to accept it, read it and archive it.

For many small businesses this simply means having an email address that can receive the files and a tool that can open and store them properly.

Step two: from 2027, larger businesses have to send

From 1 January 2027, businesses with a total turnover of more than €800,000 in the previous year have to issue e-invoices for their domestic business-to-business sales.

Smaller businesses can still send paper or PDF invoices during 2027, as long as the customer agrees. For businesses already using EDI, a transition rule applies until the end of 2027.

Step three: from 2028, everyone has to send

From 1 January 2028, every business has to issue e-invoices for domestic business-to-business sales, whatever its size. That is the point where the PDF invoice to another business effectively ends.

What is not affected

A few things stay as they are, and this is where most of the unnecessary worry comes from.

Invoices to private customers are not covered by these rules. If you sell to consumers, nothing changes there.

Small-amount invoices up to €250 and travel tickets can still be issued in other formats.

Small businesses using the Kleinunternehmer rule under § 19 UStG do not have to issue e-invoices, even after 2028. They do, however, still have to be able to receive them.

What a small business should actually do

First, make sure you can receive e-invoices today. That has been required since the start of 2025, and it is the part most small businesses have not looked at yet.

Second, find out which of the rules applies to you. Your turnover and whether you use the Kleinunternehmer rule decide your deadline for sending. This is a five-minute conversation with your tax advisor.

Third, choose a way to issue e-invoices before you are forced to. Switching in a calm month is much easier than switching in the last week of December.

Why this is a design problem, not just a legal one

Most e-invoicing tools are built for accountants. They are powerful, and they assume you already understand the standards. For a freelancer writing ten invoices a month, that is too much.

When we designed WirFaktura, the goal was the opposite. Write an invoice the way you always have, and let the product take care of the format. Every invoice is issued as XRechnung under EN 16931 and checked against the official KoSIT validator. Receiving and archiving stay free. And the product says clearly what it does not do: no bookkeeping, no tax return, no tax advice.

The law decides that invoices have to change. It does not decide that writing them has to get harder. That part is a design choice.