E-invoicing in Germany: what small businesses need to know

Receiving since 1 Jan 2025, issuing from 2027/2028: the German B2B e-invoice timeline, XRechnung vs ZUGFeRD, and what OpenBusinessERP supports.

Last checked: Sources listed at the end

Not legal or tax advice. This page summarises public rules and describes what the software does. It does not replace advice from your tax adviser. The linked official sources, in their current version, are what counts.

In short

  • Since 1 January 2025 every business established in Germany must be able to receive e-invoices from other businesses. The Federal Ministry of Finance (BMF) says an email inbox is enough for that.
  • You must issue e-invoices for supplies made from 1 January 2028 at the latest, or from 1 January 2027 if your total turnover in 2026 was above €800,000.
  • A PDF is not an e-invoice. The law means a structured format that follows the European standard EN 16931, such as XRechnung or ZUGFeRD from version 2.0.1.
  • The obligation applies between businesses in Germany (B2B). Invoices to consumers are not affected.

Timeline

The transition rules are in § 27 (38) of the German VAT Act (UStG). What counts is when the supply is made, not the invoice date.

Supply madeReceivingIssuing
1 Jan 2025 to 31 Dec 2026You must accept e-invoicesPaper, or another electronic form such as PDF if the recipient agrees, is still allowed
1 Jan 2027 to 31 Dec 2027As aboveTotal turnover in 2026 above €800,000: e-invoice required. Up to €800,000: paper or another electronic form still allowed. EDI with the recipient's consent still allowed
From 1 Jan 2028As aboveE-invoice for all domestic B2B supplies. EDI remains possible if the required data can be extracted completely and correctly in line with EN 16931

Who is exempt

According to the BMF FAQ, no e-invoice has to be issued for:

  • small-amount invoices up to €250 gross (§ 33 UStDV),
  • tickets that count as invoices (§ 34 UStDV),
  • supplies by small businesses under § 19 UStG (§ 34a UStDV),
  • supplies to consumers and to legal entities that are not businesses.

These exemptions cover issuing only. A small business still has to be able to receive e-invoices.

XRechnung or ZUGFeRD

Both implement EN 16931. The BMF names “XRechnung and ZUGFeRD from version 2.0.1 (except the profiles MINIMUM and BASIC-WL)” as meeting the requirements.

XRechnungZUGFeRD / Factur-X
FormPlain XML file, UBL or CII syntaxPDF with an embedded XML file (CII), readable by people and machines
Maintained byKoSIT, on behalf of the federal and state governmentsFeRD; Factur-X is the Franco-German equivalent
Typical useRequired for invoices to public bodies; Leitweg-ID as buyer referenceInvoices to companies that still expect a readable PDF
Qualifying profilesXRechnungEN 16931 (Comfort), EXTENDED, XRECHNUNG; not MINIMUM, not BASIC-WL

With ZUGFeRD, the XML file is the invoice. After the second amendment of the GoBD (BMF letter of 14 July 2025), what matters for retention is the structured part; the readable part only has to be kept if it carries additional tax-relevant information. The retention period for invoices is set by § 147 AO.

Receiving e-invoices

Receiving means accepting the file, reading it and keeping it unchanged. To read a plain XML file you need a viewer. Whether a file is formally correct can be checked with the free KoSIT validator, for example. The BMF notes that validation is not a condition for deducting input VAT, but it helps find errors.

What OpenBusinessERP does today

As of version 18.4.0, checked in the source code. We list what is missing too.

CapabilityStatus
Generate XRechnung 3.0 (CII syntax)Yes, on the page of the issued invoice, Leitweg-ID on the invoice
ZUGFeRD 2.1 / Factur-X 1.0, including hybrid PDFYes. Full PDF/A-3 conformance is not claimed
Peppol BIS Billing 3.0 (UBL)Yes
XRechnung in UBL syntaxNo
Leitweg-ID (BT-10)Yes, required by the XRechnung profile
Check before downloadPartly: a subset of the rules from EN 16931 (BR, BR-CO), XRechnung (BR-DE) and Peppol (R003), not the full KoSIT validator. A fatal finding blocks the download
Sending over the Peppol networkNo. There is no Peppol access point; you download the file and send it yourself
Invoices from Quotes & invoices as e-invoiceNot yet. These go out as PDF, optionally with an EPC QR code
Read incoming XRechnung or ZUGFeRDNo. There is no import for incoming e-invoices

Issuing becomes mandatory for everyone only from 2027 or 2028. If you already have to issue e-invoices, for example to public bodies, also check each file with the receiver's validator or the KoSIT validator.

What to do now

  1. Set up a fixed address for incoming invoices, such as invoices@your-company.de, and tell your suppliers.
  2. Decide how received XML files are made readable and stored unchanged.
  3. Note your total turnover for 2026: it decides whether you must issue from 2027 or from 2028.
  4. Clean up master data: VAT ID or tax number, full addresses and countries of your customers. The invoice requirements checklist helps.
  5. Agree with your accountant which format they want for documents and postings. See the DATEV export guide.

Sources

  1. § 14 UStG, issuing invoices (gesetze-im-internet.de, German)
  2. § 27 UStG, transitional rules, para. 38 (German)
  3. § 33 UStDV, small-amount invoices (German)
  4. § 34 UStDV, tickets as invoices (German)
  5. § 34a UStDV, invoices by small businesses (German)
  6. Federal Ministry of Finance (BMF): e-invoice FAQ (October 2026), referring to its letters of 15 Oct 2024, 15 Oct 2025 and 15 Oct 2026 (German)
  7. XRechnung standard and specification (KoSIT, xeinkauf.de)
  8. ZUGFeRD: Forum elektronische Rechnung Deutschland (FeRD)
  9. KoSIT validator (open source, GitHub)
  10. OpenBusinessERP: e-invoice profiles in the source
  11. OpenBusinessERP: validation rules in the source