E-invoicing requirement 2026: deadlines, exceptions and formats

What actually counts as an e-invoice?

An e-invoice is an invoice that is issued, transmitted and received in a structured electronic format and can be processed automatically. A simple PDF file sent by email does not meet this definition — legally, it now only counts as an "other invoice," just like a paper invoice. Without an embedded, machine-readable XML data format, it is not an e-invoice within the meaning of the law.

Who is affected?

Initially, only domestic B2B transactions are affected — invoices between businesses based in Germany. Invoices to private individuals or to businesses abroad are not subject to the requirement. Two practically important special cases:

• Landlords who have opted for VAT liability towards their tenants (§ 9 UStG) also count as a B2B case.
• Anyone who rents exclusively VAT-exempt to private individuals is affected on the receiving side — for example, when a tradesperson bills a renovation as an e-invoice.

Exceptions to the requirement

Two exceptions apply permanently, regardless of the transition periods:

• Small-amount invoices up to a total of €250 as well as tickets — a regular invoice is still sufficient here.
• Small businesses (Kleinunternehmer) under § 19 UStG don't have to send e-invoices — but they must be able to receive and read them.

Transition periods: by when do I have to switch?

On the receiving side, every business has had to be able to accept e-invoices since 01.01.2025 — this cannot be postponed. On the issuing side, there are three transition rules:

• Until end of 2026: all businesses may still bill via PDF, paper or another electronic format.
• Until end of 2027: additionally for businesses with a maximum of €800,000 revenue in the prior year.
• Until end of 2027: for transactions billed via an already-used EDI procedure.

Even if a transition period applies to you: large customers often already actively require e-invoices today. Switching early won't cost you those contracts.

ZUGFeRD or XRechnung — what's the difference?

According to the German Federal Ministry of Finance (BMF), both formats meet the requirements of EN 16931. For hybrid formats like ZUGFeRD, the structured XML part takes precedence in case of doubt, not the human-readable PDF image — in other words, in case of discrepancies, the machine wins over the eye.

Mandatory invoice details

E-invoice or not — the mandatory content requirements under § 14 (4) UStG don't change. If one is missing, the invoice is not proper and the recipient loses the input tax deduction:

• Full name and address of the issuer and recipient
• Tax number or VAT ID of the supplying business
• Issue date and sequential invoice number
• Quantity and description of the goods or type and scope of the service
• Date of supply
• Amount broken down by tax rate, tax amount or note on tax exemption

Retention periods

E-invoices are subject to the same retention periods as paper invoices: 8 years (since the Fourth Bureaucracy Relief Act, previously 10 years). The period begins at the end of the year of the last change to the invoice. The invoice must be retained unchanged in its original format — for ZUGFeRD, according to the updated GoBD guidance, it is sufficient to archive the structured XML part.