Germany's B2B e-invoicing reform arrives in stages, and the next one is close. Since 1 January 2025, every German business must be able to receive electronic invoices. From 1 January 2027, companies with prior-year turnover above €800,000 must issue them. From 1 January 2028, the issuing obligation applies to everyone, with narrow exceptions for small amounts.
If you are still emailing PDF invoices from a Word template, you have roughly a year to change that.
What Germany counts as an e-invoice
An e-invoice is a structured format that follows the European standard EN 16931. A plain PDF does not qualify, even if it is generated by software. The two formats you will meet most are:
- XRechnung: pure XML, originally for invoices to public authorities, now widely used in B2B too.
- ZUGFeRD (from version 2.0.1 onward, with the EN 16931 profile or higher): a hybrid PDF/A-3 file with embedded XML. It looks like the PDF invoice everyone knows, but carries the structured data inside. See Factur-X and ZUGFeRD explained.
Other EN 16931-compliant formats are allowed if both sides agree. Germany does not use a central clearance platform; invoices can travel by email, portal or Peppol.
The transition rules in one table
| Period | Receiving | Issuing |
|---|---|---|
| 2025 and 2026 | Mandatory for all | Paper or PDF still allowed |
| 2027 | Mandatory for all | Mandatory above €800k turnover; others may still send PDF with consent |
| From 2028 | Mandatory for all | Mandatory for all |
Why ZUGFeRD is popular with small businesses
ZUGFeRD lets a business move to compliant invoicing without changing what customers see. The visible page stays the same, and the embedded XML satisfies the law. Many invoicing tools already export ZUGFeRD with a setting change.
The catch is that the XML is authoritative. If you open the finished file in a PDF editor and fix a typo in the amount, the XML still has the old value. Correct the invoice in the software that generated it, and re-export.
What to do in the next twelve months
- Check your turnover against €800,000 to know whether 2027 or 2028 is your deadline.
- Test your receiving process. Can your bookkeeping read an XRechnung file, or does someone print it?
- Choose your issuing format. ZUGFeRD (EN 16931 profile) is the gentlest step for most.
- Stop the habits that break hybrid files: printing to PDF, merging invoices into bundles, compressing with tools that strip attachments.
- Archive correctly. German retention rules (GoBD) require keeping the invoice in its original format. Keep the PDF/A-3 file intact.
Where a PDF editor still helps
Plenty of the documents around an invoice stay as PDFs: quotes, delivery notes, signed contracts, approval packs. For annotating copies, adding an approval stamp, or signing a quote, a browser tool like Docento.app works without uploading the file. Just keep it away from the original hybrid invoice.
Takeaway
Germany's reform is gentler than France's or Poland's, with no central platform and a long runway, but the runway is ending. Pick an EN 16931 format, treat the XML as the invoice, and keep the PDF as the friendly face. For the rest of Europe, see France's mandate and the EU's ViDA package.
