Germany

Germany introduced mandatory B2B e-invoicing through the Growth Opportunities. The reform redefines what counts as an e-invoice. An invoice is only an e-invoice if it is issued, sent and received in a structured format that can be processed electronically and meets the European standard EN 16931. A PDF is no longer an e-invoice, even when it is sent by email.

Unlike Italy or Poland, Germany has no central clearance platform. Invoices travel directly between businesses using whichever channel they agree on, such as email, Peppol, EDI or a portal. This gives businesses flexibility, but it also means each company has to make sure its own processes and partners can handle structured data.

The reform is widely seen as a first step. Germany has signalled its plans for a reporting system for invoice data in the future, in line with the EU's ViDA package. Businesses that set up structured e-invoicing now will be ready for that next stage.

The mandate applies to domestic B2B transactions between businesses established in Germany. The receiving obligation has applied to all businesses since 1 January 2025, including small businesses under the Kleinunternehmer regime and businesses that make only VAT-exempt supplies.

The issuing obligation is phased. Businesses with prior-year turnover above €800,000 must issue e-invoices from 2027, and all other businesses from 2028. Small-value invoices up to €250 and certain tickets are exempt (verify the full list of exemptions). B2C invoices and invoices to foreign customers are outside the scope.

From January 2025, every business needs to be able to receive structured e-invoices. In practice, this means an email address or another channel for receiving invoices, plus software that can read and process XML invoice data rather than just display a PDF.

When the issuing obligation applies, invoices must be structured, compliant with EN 16931 and contain all mandatory VAT information under German law. Until the end of the transition period, other formats are allowed only with the recipient's consent. EDI invoices remain permitted if the content of the invoice can be extracted in a form that meets EN 16931 (verify the detailed rules).

E-invoices must be stored in their original structured form for the legal retention period, in line with the German rules on digital record-keeping (GoBD). Keeping only a printout or a PDF view is not enough.

The two main formats are XRechnung, the German CIUS of EN 16931 available in UBL and CII syntax, and ZUGFeRD, a hybrid PDF/A-3 with embedded XML, from version 2.0.1 using the EN 16931 profile or higher. Factur-X, the French equivalent of ZUGFeRD, is technically identical and also accepted. Other EN 16931-compliant formats can be used if both parties agree.

There is no national exchange platform for B2B. Businesses can send invoices by email, over Peppol, by EDI or through portals. For public-sector invoices, suppliers use the federal and state invoice portals or Peppol, and identify the recipient with a Leitweg-ID.

HubBroker connects your ERP to every channel your German trading partners use, whether that is email, Peppol, EDI or the public-sector portals. We map your invoice data to XRechnung or ZUGFeRD, validate it against EN 16931 and the German business rules, and deliver it in the format each customer requires.

On the receiving side, inbound e-invoices arrive in your ERP as structured data, ready to post. During the transition period, many suppliers will still send PDFs. HubBroker's IDP extracts the data from them, so your accounts payable team can work in one digital flow instead of a mix of formats.

You keep your existing ERP, whether that is Dynamics 365, Business Central, SAP Business One or another system. HubBroker handles the formats, validation and connections, so you are ready for the 2027 and 2028 deadlines without a system change.