Germany's e-invoicing mandate: what freelancers need to know by 2028
Since 1 January 2025, businesses in Germany must be able to receive e-invoices. Transition periods for issuing them run until the end of 2027. An overview for freelancers and small businesses.
Updated 19 October 20262 min read
With the Growth Opportunities Act (Wachstumschancengesetz), electronic invoices became mandatory for sales between businesses in Germany (B2B). The obligation arrives in stages. Knowing what applies when lets you plan the switch calmly instead of changing software in a hurry just before a deadline.
What counts as an e-invoice?
An e-invoice is not simply a PDF sent by email. It is an invoice in a structured electronic format that software can read automatically and that complies with the European standard EN 16931. In Germany, that mainly means XRechnung and ZUGFeRD from the BASIC profile upwards. A plain PDF invoice counts as an “other invoice”.
The deadlines at a glance
| Period | Receiving e-invoices | Issuing invoices |
|---|---|---|
| 2025 and 2026 | Mandatory | Paper and PDF still allowed, PDF only with the recipient's consent |
| 2027 | Mandatory | Paper and PDF only with prior-year revenue up to €800,000, otherwise e-invoices |
| From 1 January 2028 | Mandatory | E-invoices for all domestic B2B sales |
Invoices exchanged via EDI, as some larger companies use, may continue until the end of 2027 with the recipient's consent.
Who is affected, and who isn't?
- Invoices between businesses based in Germany are affected. That includes freelancers and the self-employed.
- Invoices to private individuals (B2C) are not affected.
- Small-amount invoices up to €250 gross and travel tickets may still be issued on paper or as PDF.
- Small businesses under § 19 UStG (Kleinunternehmer) don't have to issue e-invoices, but have had to be able to receive them since 2025.
Receiving: what you need already
An email inbox is usually enough to receive e-invoices. What matters is that you can read the files and archive them properly: the structured file, the XML, is the original and must be stored unchanged. A printout is not enough. Many accounting programs and free viewers display XRechnung and ZUGFeRD in readable form.
Issuing: how to prepare
- Check your revenue. If it was €800,000 or less in the previous year, you have until the end of 2027 for issuing.
- Ask your business clients which format they can process. ZUGFeRD is often the easiest for small businesses, because people can still read the invoice as a PDF.
- Choose invoicing software that creates XRechnung and ZUGFeRD, and check your first invoices with a validator.
- Adapt your records: keep e-invoices electronically and unchanged, generally for eight years since 2025.
This article is a general overview (as of October 2026) and is not tax advice. Please check with your tax advisor what applies in your case.