Germany e-invoicing for all businesses — January 2028
From 1 January 2028, every German business must issue structured e-invoices for all domestic B2B transactions, regardless of size or turnover. This completes Germany's three-phase e-invoicing rollout under § 14 UStG. One exception: small businesses without VAT registration under § 19 UStG are exempt from the issuance obligation.
Last updated: 2026-06-01
2025-01-01
E-invoice receipt obligation
All German businesses must be able to receive and process structured e-invoices.
§ 14(1) UStG — Wachstumschancengesetz (BGBl. 2024 I Nr. 108)
2027-01-01
E-invoice issuance — large companies
Companies with prior-year turnover above €800,000 must issue structured e-invoices.
§ 14(3) UStG — Wachstumschancengesetz (BGBl. 2024 I Nr. 108)
2028-01-01
E-invoice issuance — all businesses
All German businesses must issue structured e-invoices for domestic B2B transactions. Exception: small businesses without VAT registration (§ 19 UStG) are exempt from the issuance obligation.
§ 14(3) UStG — Wachstumschancengesetz (BGBl. 2024 I Nr. 108)
Frequently asked questions
Are small businesses (§ 19 UStG) exempt?▼
Small businesses that do not charge VAT (§ 19 UStG) are exempt from the issuance obligation. However, the receipt obligation applies to all businesses since January 2025.
Does the mandate apply to B2C and cross-border invoices?▼
No. The e-invoicing mandate applies only to domestic B2B transactions between German businesses. B2C and cross-border transactions are excluded.
Which formats are accepted from 2028?▼
Any EN 16931-compliant format: XRechnung (UBL 2.1 or CII), ZUGFeRD 2.x (COMFORT profile or above), and Factur-X. From 2028, EDI processes without EN 16931 compliance are no longer permitted.
What do SMEs need to prepare?▼
Check early whether your software can output EN 16931-compliant e-invoices. Test your outgoing invoices with the batch validator. Train your accounts team on structured e-invoice handling. Don't wait until late 2027 to start.
Can I start issuing e-invoices before the 2028 deadline?▼
Yes — and it's recommended not to wait until January 2028. Since January 2025, all German businesses can receive e-invoices; issuing them is technically possible now for most systems. Earlier adoption reduces last-minute pressure and allows sufficient testing time.
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