B2B E-Invoicing Obligations in Germany: Deadlines, How to Create, and Receive

Germany's B2B e-invoicing mandate requires businesses to issue and receive invoices in structured electronic formats (EN 16931 compliant) such as XRechnung and ZUGFeRD. The rollout begins January 2025 with full mandatory issuance for all businesses by January 2028.

Key Takeaways

• All businesses must be capable of receiving EN 16931-compliant e-invoices from 1 January 2025.
• Companies with turnover exceeding €800,000 must issue e-invoices from 1 January 2027; all others by 1 January 2028.
• Acceptable formats include XRechnung, ZUGFeRD 2.1+, Peppol BIS 3.0, and EN 16931-compliant EDI.
• Simple PDFs and paper invoices will no longer qualify as valid invoices for VAT deduction after transition periods.
• No central government portal exists; transmission occurs via email, EDI, Peppol, or ERP integration.

What is B2B E-Invoicing in Germany?

B2B e-invoicing in Germany refers to issuing, transmitting, and receiving invoices in a structured electronic format that enables automated, end-to-end electronic processing. For VAT purposes, Germany distinguishes between:

• E-invoice (E-Rechnung): a structured invoice that can be electronically processed, typically aligned to EN 16931.
• Other invoices: paper invoices and unstructured electronic invoices, such as a basic PDF that cannot be automatically processed as structured data.

The reform targets domestic B2B transactions between businesses established in Germany. Consumers are generally not part of the new B2B mandate, and business-to-government invoicing has separate, long-running requirements and portals.

Scope of Germany's E-Invoicing Mandate

The mandate covers specific transaction types and business categories.

• Applies to all domestic B2B transactions within Germany
• Both supplier and buyer must be VAT-registered businesses established in Germany
• Cross-border transactions (intra-EU and international) are excluded
• B2C invoices to private consumers are not covered
• Small-value invoices under €250 are exempt
• Specified VAT-exempt supplies fall outside the requirement

Why Germany is Changing How B2B Invoices Work?

Structured e-invoicing delivers measurable operational advantages for both suppliers and buyers.

• Reduced processing time: Automated data import eliminates manual entry delays.
• Improved accuracy: Standardized fields prevent transcription errors and data mismatches.
• Faster payment cycles: Straight-through processing enables quicker invoice approval and payment.
• Audit readiness: Structured records simplify VAT reporting and tax authority verification.
• Cost reduction: Lower administrative overhead compared to paper-based workflows.

Key Deadlines for B2B E-Invoicing in Germany

Germany has established a phased implementation timeline that progressively expands e-invoicing obligations based on business size and activity type.

Acceptable Formats for B2B E-Invoicing in Germany

Germany accepts any invoice format that complies with the European standard EN 16931 and enables automatic electronic processing. The primary formats recognized for compliance are outlined below.

1. XRechnung

XRechnung is Germany's official e-invoice standard, developed as the German Core Invoice Usage Specification (CIUS) of EN 16931. It defines a structured XML schema containing all mandatory invoice elements required by German VAT law and public administration.

XRechnung can be implemented using either UBL (Universal Business Language) or UN/CEFACT CII (Cross Industry Invoice) XML syntaxes. Both are equally valid for compliance purposes. The format has been mandatory for B2G (business-to-government) invoicing since 2020 and is now extending to B2B transactions.

2. ZUGFeRD

ZUGFeRD (Zentraler User Guide des Forums elektronische Rechnung Deutschland) is a hybrid format combining a human-readable PDF with an embedded XML data file. This dual structure allows recipients to view the invoice visually while extracting structured data for automated processing.

For B2B e-invoicing compliance, businesses must use ZUGFeRD version 2.0.1 or later with profiles that meet EN 16931 requirements. The following profiles are acceptable.

• EN 16931 (Comfort) profile: Fully compliant with the European standard.
• Extended profile: Contains additional data beyond the standard but remains compliant.

3. UBL (Peppol BIS 3.0)

Peppol BIS Billing 3.0 is an international e-invoicing format based on UBL 2.1 and aligned with EN 16931. Businesses using Peppol network infrastructure or international invoicing solutions that output BIS-compliant invoices can use this format for German B2B transactions.

The technical content of Peppol BIS 3.0 is closely aligned with XRechnung, ensuring interoperability between formats. Invoices transmitted via Peppol Access Points using this format satisfy German e-invoicing requirements.

4. EDI Formats (EDIFACT)

Existing EDI arrangements using formats such as EDIFACT INVOIC may continue under certain conditions. The German Ministry of Finance confirmed that EDI formats remain acceptable if they contain all information required by VAT law and can be mapped to EN 16931 data elements.

Businesses using EDI must ensure their messages include all mandatory invoice fields. Where gaps exist, EDI implementations may require updates to add missing elements such as buyer references or specific tax codes.

Formats Not Accepted

The following formats do not qualify as e-invoices under German law.

• PDF without embedded XML: Simple PDF files cannot be processed automatically and are excluded.
• Scanned paper invoices: Image files lack structured data and are not compliant.
• Word documents or email text: These formats do not meet the structured electronic format requirement.
• ZUGFeRD Minimum or Basic-WL profiles: Insufficient data content for EN 16931 compliance.

Format selection quick guide

How to Send and Receive E-Invoices in B2B Transactions

Germany’s B2B framework requires businesses to design a compliant operational process that covers structured invoice creation, validation, secure transmission, controlled receipt, and audit-ready archiving across multiple channels.

Here are the general requirements and process to follow

Mandatory Invoice Data Elements

German VAT law and EN 16931 require specific information on every invoice. The table below lists essential fields.

Sending B2B E-Invoices In Germany: Step-by-Step Process

The following steps outline a typical B2B e-invoice transmission workflow.

1. Generate the invoice in your accounting system: Create the invoice with all required data elements including VAT information, line items, buyer reference (if applicable), and totals.
2. Export in a compliant format: Convert the invoice to XRechnung XML, ZUGFeRD PDF/XML, or another EN 16931-compliant format supported by your system.
3. Validate the invoice: Run the invoice through validation tools to check XML structure, mandatory fields, and business rule compliance before transmission.
4. Transmit via agreed channel: Send the invoice file through the method agreed with your trading partner, whether email attachment, EDI connection, Peppol network, or direct system integration.
5. Retain transmission records: Archive the sent invoice and any delivery confirmations for audit purposes. German law requires ten-year retention of invoice records.

Receiving B2B E-Invoices in Germany: System Requirements

Businesses must prepare their systems to receive and process incoming e-invoices from 1 January 2025. The following capabilities are essential.

• Format compatibility: Systems must import XRechnung and ZUGFeRD formats at minimum.
• Validation capability: Incoming invoices should be validated against schema and business rules.
• Data mapping: Invoice fields must map correctly to accounting system records.
• Exception handling: Processes for managing invalid or incomplete invoices must be defined.
• Archiving: Electronic invoices must be stored in their original format for ten years.

Steps to implement receiving capability 

Receiving is the first hard date that affects everyone. “We can open PDFs” is not sufficient for B2B e-invoicing readiness.

• Step 1: Select at least one accepted format you will support for inbound invoices, then test it end-to-end.
• Step 2: Set up an intake channel with clear ownership, such as a dedicated mailbox, Peppol access point, portal, or integration endpoint.
• Step 3: Implement parsing and posting rules in AP, including tax code mapping and PO matching logic.
• Step 4: Define a validation layer that flags missing required fields and calculation errors.
• Step 5: Establish an exception workflow for mismatches, including who contacts the supplier and how corrections are handled.
• Step 6: Confirm archiving method and retention approach for structured files and audit evidence.
• Step 7: Train AP teams on hybrid formats so the PDF view does not override the structured data during posting.

E-Invoices Transmission Channels in Germany

Germany does not mandate a specific transmission method or central government portal for B2B e-invoices. Businesses may select from multiple channels based on trading partner agreements, technical capabilities, and transaction volumes.

How Sender, Channel, And Format Fit Together

Because Germany does not mandate a single B2B transmission method, businesses must deliberately match formats and channels to each partner type. The table below provides a practical routing framework.

Common Mistakes to Avoid

Transitioning to B2B e-invoicing introduces compliance risks that businesses should proactively address.

The following errors frequently cause invoice rejection or compliance issues.

• Sending only PDF files: From 2025, unstructured PDFs without embedded XML do not qualify as e-invoices and may be rejected or deemed invalid for VAT deduction.
• Missing mandatory fields: Omitting buyer references, VAT identification numbers, or required tax codes can cause processing failures or legal non-compliance.
• Using outdated ZUGFeRD profiles: Minimum and Basic-WL profiles lack required data and are not compliant with the mandate.
• Incorrect XML structure: Schema errors or invalid data types prevent automatic processing by recipient systems.
• Delayed system updates: Failing to upgrade accounting software before deadlines creates last-minute compliance gaps.
• No partner coordination: Not confirming preferred formats and channels with trading partners leads to transmission failures.
• Improper archiving: E-invoices must be retained electronically in their original format for ten years; converting to PDF-only archives may violate retention requirements.

Practical Controls to Prevent Rejections and Payment Delays

Here is how you can ensure maximum e-invoicing compliance in Germany

Pre-send controls

Add these controls before an invoice leaves your system.

• Validate invoice totals and VAT amounts against tax code rules.
• Enforce required references for key customers, such as PO number formats.
• Block duplicates by enforcing uniqueness rules for invoice number and supplier identifier.
• Validate that the invoice format profile matches your trading partner agreement.

Receive-side controls

These controls protect AP operations and reduce fraud risk.

• Restrict intake to approved channels and monitor for unauthorized changes.
• Validate that inbound invoices are machine-readable and aligned to supported formats.
• Use three-way match rules where applicable and escalate exceptions with clear SLAs.
• Use a consistent archiving strategy that retains structured files and evidence.

Conclusion

Germany's B2B e-invoicing mandate represents a fundamental shift from document-based to data-based invoice exchange. Businesses that view this transition as a compliance exercise alone miss the operational efficiency gains that structured invoicing delivers. 

The phased timeline provides preparation runway, but early adoption positions businesses to streamline accounts payable and receivable processes while avoiding last-minute system overhauls. Trading partners increasingly expect e-invoice capability, making readiness a competitive factor beyond regulatory obligation.

Government Resources and Official Portals