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For foreign companies billing German B2B customers

Selling to Germany? Here's what changed.

Since January 1, 2025, Germany requires structured electronic invoices (not just PDFs) for domestic B2B transactions. If you invoice German business customers, here's what actually applies to you — and what doesn't.

Quick answer
The short version
Domestic German B2BMandate applies
Cross-border (you → Germany)Mandate does not apply
Required formatsZUGFeRD or XRechnung
Full mandate from2028
The important distinction

The mandate is domestic-only — but there's a real reason to care anyway.

Germany's e-invoicing mandate (introduced via the Wachstumschancengesetz) legally applies only to invoices between two companies established in Germany. If your company is based abroad and invoices a German business customer, you are not legally required to issue a ZUGFeRD or XRechnung invoice under this specific law.

In practice, though: your German customers are rapidly adopting e-invoicing internally to receive from domestic suppliers — and once their accounts-payable workflow expects structured e-invoices, sending them a plain PDF can mean slower processing, manual re-entry on their end, or a request to resend in the correct format. Being able to send a real ZUGFeRD/XRechnung invoice on request is becoming a practical expectation, even where it isn't a legal one.

The mandate, briefly

What's actually changing in Germany

Since Jan 1, 2025

Every company established in Germany must be able to receive and process structured e-invoices — regardless of size.

2025 – 2026

German companies may still send paper or plain PDF invoices to each other during this transition window.

2027

German companies with prior-year revenue above €800,000 must send e-invoices for domestic B2B sales. Smaller companies get one more year.

From 2028

All domestic German B2B invoices must be real e-invoices (ZUGFeRD or XRechnung) — no exceptions.

What actually counts

A PDF by email is not an "e-invoice" under this law.

A German e-invoice conforms to the European standard EN 16931 — a machine-readable structured format, not just a nicely formatted document. In practice this means one of two formats:

XRechnung — pure XML, no visual layout of its own, mandatory for invoices to German public-sector bodies (B2G) since 2020.
ZUGFeRD — a normal, human-readable PDF with the same structured XML embedded inside it, so it opens and reads like any other invoice while still carrying the required machine-readable data. Most commonly used for B2B.

FAQ

Common questions from foreign companies

I'm a US/UK/EU company invoicing a German customer. Am I legally required to use ZUGFeRD or XRechnung?

No — the mandate covers domestic German-to-German B2B transactions. Cross-border invoices you send to a German customer are not covered by this specific law.

Then why would I bother?

Because your German customer's own accounts-payable process is adapting to structured e-invoices for their domestic suppliers, and some will simply prefer — or eventually request — the same format from you, even without a legal requirement. It also signals you understand how they operate.

Does this apply if I invoice a German public-sector body (government, university, etc.)?

Yes, differently: XRechnung has been mandatory for invoices to German federal public-sector bodies since 2020, regardless of where the invoicing company is based.

Can easy-invoice24 generate both formats?

Yes — ZUGFeRD and XRechnung from the same invoice data, chosen per invoice.

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