At a glance: Since 1 January 2025, every domestic B2B company must be able to receive e-invoices. Issuing becomes mandatory in stages up to 2028. For receiving, a PDF is no longer enough; what is required are structured formats to EN 16931, in Germany above all XRechnung and ZUGFeRD. Anyone who proceeds in a structured way keeps the transition under control in three phases: as-is review, pilot operation, roll-out.

The e-invoicing mandate came into force for B2B in Germany on 1 January 2025. To many mid-sized companies the term sounds bureaucratic; in practice it is a clear catalogue of requirements. Anyone who understands the five action points gets through it without last-minute stress.

What exactly is an e-invoice?

An e-invoice is not a PDF sent by e-mail. An e-invoice is a structured XML file to EN 16931 that can be processed automatically. Two formats are relevant in Germany:

  • XRechnung: a pure XML file, mandatory for the public sector since 2020 and accepted in B2B as well from 2025
  • ZUGFeRD: a hybrid of PDF and embedded XML, readable by both people and machines

Both formats are standardised to EN 16931. Both can be archived in a way that is aligned with GoBD.

Which deadlines apply?

The mandate is being phased in, depending on revenue and the role of the company:

  1. from 1 January2025Receiving mandatoryfor all B2B companies, regardless of revenue
  2. from 1 January2027Issuing mandatoryfor companies with prior-year revenue above 800,000 euros (§ 27 (38) UStG)
  3. from 1 January2028Issuing mandatoryfor all B2B companies

What you need to do now

1. Establish an intake channel. You need a reliable intake channel, typically a dedicated e-mail address for e-invoices or a PEPPOL connection. That address has to be communicated.

2. Make sure validation happens. Incoming e-invoices have to be validated against the EN 16931 standard. Faulty e-invoices should be queried and requested again in corrected form, otherwise you put your input VAT deduction at risk.

3. Adapt the workflow. E-invoices should flow straight into the approval workflow. That is where the day-to-day benefit shows: fewer typing errors, early payment discount deadlines visible sooner, clearer audit trails.

4. Archiving aligned with GoBD. The XML file is the original. Archive the XML and the PDF together, with an identical timestamp and unalterable.

5. Inform your suppliers. Send your top 50 suppliers a note with the receiving address for e-invoices and your preferred format.

Avoiding five typical mistakes

  • Accepting PDFs as e-invoices, which they are not under EN 16931
  • Forgetting validation, so faulty mandatory fields go unnoticed
  • No Leitweg-ID for public authorities, so the invoice is rejected
  • Archiving an e-invoice like a PDF, which breaches the GoBD
  • Waiting for a software update to the existing ERP, which can take a while

The three-phase plan

Phase 1: as-is review. Which suppliers send invoices today? Which formats? Which volumes? Who is responsible internally?

Phase 2: pilot operation. Set up a dedicated e-mail address and ask two or three cooperative suppliers to take part in the pilot operation. Test validation, run through the workflow, check archiving.

Phase 3: roll-out. Inform the remaining suppliers, communicate the receiving address officially, train the accounting team.

FAQ

Do we also have to be able to issue e-invoices from 2025? Issuing becomes mandatory from 1 January 2027 for companies with prior-year revenue above 800,000 euros, and from 1 January 2028 for all B2B companies (§ 27 (38) UStG).

Is a PDF invoice with XRechnung-style content enough? No. An e-invoice has to be a structured XML file to EN 16931.

What about invoices below 250 euros? Small-amount invoices may still be issued as a PDF or on paper.

Which format should you prefer, XRechnung or ZUGFeRD? ZUGFeRD is readable by both people and machines, which usually makes it the more pragmatic choice in B2B. XRechnung is mandatory for public administration.

How long do e-invoices have to be archived? Eight years (§ 14b UStG, since 2025; ten before that), aligned with GoBD: unalterable, readable, with an audit trail. The structured XML is the original here.

Conclusion

The e-invoicing mandate is not an option, it is reality. The pragmatic route: a three-phase plan, pilot operation with cooperative suppliers, then roll-out. As at September 2026

This article provides general information on legal requirements and is no substitute for legal or tax advice in an individual case.

Further reading

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