- Business terms
- BT-10 Buyer reference
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With the Growth Opportunities Act (Wachstumschancengesetz), the electronic invoice gradually became mandatory for domestic B2B transactions in Germany. This page gives international readers an overview of the requirements for e-invoices to and within Germany: legal basis, deadlines, transition rules and accepted formats – as of October 2026.
Legal basis
The mandate is based on the VAT changes of the Growth Opportunities Act (Wachstumschancengesetz) of 27 March 2024 (BGBl. 2024 I No. 108). It applies to supplies made after 31 December 2024 and concerns only transactions between businesses established in Germany (domestic B2B) – not business with consumers.
Since 1 January 2025, Section 14 (1) sentence 3 of the German VAT Act (UStG) defines an electronic invoice as an invoice that is issued, transmitted and received in a structured electronic format and allows electronic processing. Under Section 14 (1) sentence 6 UStG, this format must comply with the European standard on electronic invoicing – EN 16931, to which Directive 2014/55/EU refers – or be agreed between the parties and be convertible into such a format without loss of information. All other invoices, on paper or in another electronic format, are "other invoices" (Section 14 (1) sentence 4 UStG).
The deadlines
| From | What applies |
|---|---|
| 1 January 2025 | All domestic businesses must be able to receive e-invoices – regardless of turnover or size. |
| until 31 December 2026 | Transition: invoices may still be issued on paper or – with the recipient's consent – in other electronic formats (e.g. PDF). |
| 1 January 2027 | Businesses with a previous-year turnover of more than EUR 800,000 must issue e-invoices. |
| until 31 December 2027 | Transition for businesses with a previous-year turnover of up to EUR 800,000 and for EDI procedures that do not comply with EN 16931. |
| 1 January 2028 | All businesses must issue e-invoices in domestic B2B transactions. |
Obligation to receive despite the transition rules
The transition rules for 2025 to 2027 only concern sending. All domestic businesses have had to receive and process e-invoices since 1 January 2025 – because every invoice issuer may already waive the transition rules and send e-invoices. The recipient's consent is no longer required for this. This also applies to small businesses (Kleinunternehmer) and to businesses that only make VAT-exempt supplies themselves.
What is an e-invoice – and what is not?
Compliant formats are in particular XRechnung, which has long been used in public procurement, and the hybrid ZUGFeRD format from version 2.0.1: a PDF/A-3 document with an embedded XML file. The German Federal Ministry of Finance (BMF) first named these formats in preliminary notes of 2 October 2023 and confirmed them in the BMF letters of 15 October 2024 and 15 October 2025 – but not the ZUGFeRD profiles MINIMUM and BASIC WL, which do not contain all mandatory details (see the profile comparison). Other formats are possible if they meet the requirements of EN 16931.
By contrast, a PDF invoice sent by e-mail without a structured data set, a scan or an invoice in the body of an e-mail is not an e-invoice. Such invoices are only permitted under the transition rules and with the recipient's consent.
What the second BMF letter (15 October 2025) clarifies
- The structured part prevails: with ZUGFeRD, the XML is the authoritative invoice; the PDF is only the visual representation. All mandatory details under Sections 14 and 14a UStG must be in the XML; a reference to an attachment or a link is not sufficient.
- Three types of errors: format errors (e.g. the XML does not comply with EN 16931) turn the e-invoice into an "other invoice". Business rule errors only matter if they concern mandatory details – a missing value such as the buyer reference (BT-10) is harmless for VAT purposes as long as it is not a mandatory detail. Content errors (e.g. a wrong VAT rate) affect input VAT deduction as before.
- Validation: validation tools help, but do not replace checking the content. Anyone who validates carefully may rely on the result regarding format and business rules; the validation report should be kept.
- Retention: the structured data set must be kept unchanged for eight years – storing only the PDF image is not sufficient.
Exceptions
- Small-amount invoices up to EUR 250 (gross) and travel tickets may still be issued as other invoices.
- Small businesses (Kleinunternehmer) do not have to issue e-invoices, but must be able to receive them.
- Invoices to private individuals (B2C) and to recipients abroad are not covered by the domestic B2B mandate.
What businesses should do now
- Ensure receipt: e-invoices must be read, checked and archived in compliance with GoBD – the XML is the authoritative original.
- Prepare sending: extend your invoicing software or ERP so that it creates XRechnung or ZUGFeRD (EN 16931 profile). If you only write a few invoices, you can also create e-invoices online in the browser without your own software.
- Check master data: mandatory details such as the VAT ID (BT-31), contact details and payment information must be available in structured form.
Implementation with the Aloaha ZUGFeRD SDK
The Aloaha ZUGFeRD SDK adds creating, reading and checking e-invoices to existing software – on-premise, without a cloud, for .NET, COM/VB6, the command line and as a web service. Getting started: quick start with VB.NET · free trial licence.
Frequently asked questions
When does the e-invoicing mandate in Germany apply?
Since 1 January 2025, all domestic businesses must be able to receive e-invoices. The obligation to issue them applies from 1 January 2027 for businesses with a previous-year turnover of more than EUR 800,000 and from 1 January 2028 for all businesses.
Is a PDF invoice an e-invoice?
No. A plain PDF invoice – even when sent by e-mail – is an "other invoice". A ZUGFeRD invoice, by contrast, is a PDF/A-3 with embedded, structured XML and counts as an e-invoice from the BASIC profile upwards; the XML is authoritative.
Does the recipient have to consent to an e-invoice?
No. Since 1 January 2025, the recipient's consent is no longer required for e-invoices within the meaning of Section 14 UStG. Consent is only required if the recipient is to receive a PDF or another "other" electronic invoice during the transition period.
Does the e-invoicing mandate also apply to private customers?
No. The mandate only concerns supplies between domestic businesses (B2B). Invoices to consumers can still be issued on paper or as a PDF.
Are there exceptions to the e-invoicing mandate?
Yes, among others for small-amount invoices up to EUR 250 and travel tickets. Small businesses do not have to issue e-invoices, but must be able to receive them.
Business terms in this article: BT-10