E-Invoicing Exemptions in Germany: Revenue Thresholds, and Special Cases

Germany’s e-Invoicing rules apply only to domestic taxable B2B invoices, with many exemptions. Structured formats such as XRechnung or ZUGFeRD matter, but obligations differ by invoice type, turnover, and timing, with receipt mandatory from 2025 and wider issuance from 2027 to 2028.

Key takeaways

• Domestic taxable B2B invoices are generally in scope, while B2C transactions, VAT-exempt supplies, and non-entrepreneur recipients are usually outside scope. 
• Invoices up to EUR 250, passenger transport tickets, and qualifying VAT-exempt supplies remain permanently exempt from structured issuance requirements. 
• Kleinunternehmer (Small busineses) may continue using non-structured invoices through December 31, 2027, but they still must be able to receive compliant e-invoices from 2025. 
• Restaurants, associations, nonprofits, and cross-border cases often require invoice-by-invoice classification because scope depends on transaction type, customer status, and tax treatment. 

What E-Invoicing Obligations Mean in Germany

Germany’s regime is not a blanket rule for every invoice. It applies to domestic B2B transactions where the supplier and recipient are established in Germany and the supply is taxable.

What Counts as an E-Invoice

An e-invoice must be issued, sent, and received in a structured electronic format that supports automated processing. In practice, that means formats aligned with EN 16931, such as XRechnung or ZUGFeRD. A PDF sent by email may still be electronic, but it is not treated as an e-invoice for mandate purposes.

What Became Mandatory From 2025

From January 1, 2025, all covered businesses must be capable of receiving structured e-invoices for domestic B2B transactions. That requirement applies even if the business is not yet required to issue them.

For many businesses, this is the first compliance step. The receiving obligation is immediate, while the issuing obligation is phased in over time.

Who Is in e-Invoicing Scope

The following framework helps determine whether the rule applies at all.

E-Invoicing Exemptions in Germany

According to Germany's latest official e-invoicing guidelines under the Growth Opportunities Act. Here are the major Germany e-Invoicing exceptions that matter most in practice.

1. €800,000 Turnover Threshold

A business whose prior-year turnover does not exceed €800,000 may continue issuing paper or non-structured electronic invoices through December 31, 2027. If prior-year turnover exceeds that amount, structured issuance becomes mandatory from January 1, 2027.

This turnover test is based on prior-year entrepreneurial revenue. It is not limited to one business segment, and group situations require extra care because the relevant turnover may be measured at group level rather than entity level.

2. €250 Low-Value Invoice Exemption

Invoices with a total amount up to €250, including VAT, remain permanently exempt from the structured e-invoicing requirement.

This is a document-level exception, not a business-level one. A company that is otherwise fully subject to e-invoicing may still issue a paper or PDF invoice when the gross amount is €250 or less. Once the amount exceeds that figure, the normal rules apply.

3. Kleinunternehmer Exemption Through 2027

Businesses using the German small business scheme under Section 19 UStG may continue issuing non-structured invoices through December 31, 2027. They still must be able to receive structured e-invoices from January 1, 2025.

From January 1, 2028, this format relief ends. Their VAT status may remain unchanged, but the invoice format must then follow the e-invoicing rules for domestic B2B transactions.

4. VAT-Exempt Supplies

VAT-exempt supplies fall outside the e-invoicing mandate because the regime is tied to taxable domestic B2B transactions. Typical exempt areas include certain financial, medical, educational, and real estate supplies under Section 4 UStG.

Where a transaction includes both taxable and exempt elements, the treatment depends on the nature of the overall supply. That is why mixed invoices require careful classification before assuming an exemption applies.

5. Supplies to Non-Entrepreneurs

Invoices issued to consumers are outside the domestic B2B mandate. The same logic can apply where the recipient is not acting as an entrepreneur.

This distinction is critical because many businesses issue both B2B and B2C invoices. The same supplier may be outside scope for one invoice and inside scope for the next, depending on the customer’s status.

Who Must Issue E-Invoices in Germany

The cleanest way to assess the rule is to test each invoice in order.

Step 1: Check Whether the Invoice Is a Domestic Taxable B2B Invoice

If the invoice is for a domestic taxable B2B transaction, it is potentially within scope. If it is B2C, VAT-exempt, or issued to a non-entrepreneur, it is generally outside the mandate.

Step 2: Check for Permanent Exemptions

The following invoices remain outside the structured issuance requirement:

• invoices up to €250, including VAT
• passenger transport tickets
• qualifying VAT-exempt supplies

Step 3: Check for Transitional Relief

If no permanent exemption applies, the next question is timing.

• Businesses with prior-year turnover above €800,000 must issue structured e-invoices from January 1, 2027.
• Businesses at or below €800,000 may continue paper or PDF invoices through 2027.
• Kleinunternehmer may also continue non-structured issuance through 2027.
• From January 1, 2028, structured issuance becomes the default for all remaining in-scope domestic B2B invoices.

Special Cases That Commonly Cause Confusion

A few edge cases deserve separate attention because businesses often misclassify them.

1. Restaurants

Restaurant receipts issued to diners are usually B2C and therefore outside the domestic B2B mandate. However, a restaurant billing another business for catering or corporate events must follow the normal timeline for B2B issuance.

2. Associations and Nonprofits

Associations are not automatically exempt. The deciding factor is whether the activity is entrepreneurial or non-commercial. A nonprofit may be outside scope for grants or member contributions, but inside scope for taxable business sales to other businesses.

3. Cross-Border Transactions

Germany’s domestic B2B mandate does not apply in the same way to cross-border transactions. If one party is established outside Germany, different VAT and digital reporting rules may apply instead of the domestic e-invoicing timeline.

Conclusion

Germany’s e-invoicing reform is best understood as a classification exercise, not a single deadline. Businesses that separate domestic B2B invoices from exempt, low-value, and non-entrepreneurial transactions can apply the rules with far less friction. The real compliance advantage lies in mapping invoice types early, because the 2027 turnover trigger and the universal 2028 rollout leave little room for last-minute interpretation.