E-invoicing in Germany: the mandate explained for founders
Since January 1, 2025, every business in Germany must be able to receive B2B e-invoices. The obligation to send them is phased in: from 2027 for businesses with more than €800,000 in total turnover in the prior year, from 2028 for everyone (§ 14(2) and § 27(38) UStG).
When does the mandate apply?
Germany introduced mandatory e-invoicing with the Growth Opportunities Act (Wachstumschancengesetz) of March 27, 2024 (BGBl. 2024 I No. 108), and it has applied since January 1, 2025. It covers supplies to another business for its business where both are established in Germany, so the B2B side (§ 14(2) sentence 2 no. 1 UStG, German). The transition periods are set out in § 27(38) UStG (German).
This guide is for businesses in Germany, written with founders in mind: online shops on Shopify, creators and publishers who get paid through Stripe or Ghost, and SaaS startups that bill other companies.
Receiving and sending are two separate obligations. You have had to be able to receive e-invoices since 2025. You only have to send them later, on a schedule that depends on your prior-year revenue.
What that means for typical setups:
- You sell only to consumers (a typical D2C shop): those invoices are B2C and outside the mandate. You still have to be able to receive e-invoices, for example from your suppliers.
- You sell to other businesses in Germany (B2B SaaS, agencies, wholesale): you must send e-invoices from January 1, 2027 if your total turnover in the prior year was more than €800,000, and from January 1, 2028 otherwise.
Timeline 2025 to 2028
- Since January 1, 2025: the e-invoice is the standard form for domestic B2B invoices. Every business must be able to receive e-invoices (section 14.1(4) and (5) UStAE, German).
- January 1, 2025 to December 31, 2026: transition period. For sales made in this period you may still issue an "other invoice" (sonstige Rechnung). Paper invoices remain allowed during the transition, while a PDF or another electronic format requires the recipient's consent (§ 27(38) no. 1 UStG, German).
- From January 1, 2027: businesses with more than €800,000 in total turnover in the prior year must send e-invoices for B2B sales.
- Until December 31, 2027: businesses with total turnover of up to €800,000 in the prior year may still issue other invoices for sales made in 2027 (§ 27(38) no. 2 UStG, German). Invoices sent through EDI remain allowed for everyone until the end of 2027 if the recipient agrees (no. 3).
- From January 1, 2028: all businesses must send e-invoices for B2B sales.
- Since Jan 1, 2025All businesses must be able to receiveTransition period for sending until Dec 31, 2026: paper still allowed, PDF only with the recipient's consent
- From Jan 1, 2027Sending required above €800,000 prior-year revenueUp to €800,000, other invoices remain allowed until Dec 31, 2027
- From Jan 1, 2028Sending required for all businessesE-invoices for everyone
Receiving e-invoices since 2025
The obligation to receive has applied since January 1, 2025. The transition rules in § 27(38) UStG only cover issuing invoices, and there is no revenue threshold for receiving them. Every business in Germany must have the technical means to receive e-invoices, including small businesses that still send paper or PDF invoices themselves (section 14.1(5) UStAE, German). In practice you need an email address for incoming invoices (a separate mailbox just for e-invoices is not required) and software that can read a format under EN 16931.
Exceptions and special cases
Not every invoice falls under the mandate. Exempt are, among others, invoices to consumers (B2C), small-amount invoices up to €250 (§ 33 sentence 4 UStDV, German), passenger tickets (§ 34(1) sentence 2 UStDV) and invoices from small businesses under the Kleinunternehmer scheme (§ 34a sentence 4 UStDV). Sales that are VAT-exempt under § 4 nos. 8 to 29 UStG carry no invoicing obligation in the first place (§ 14(2) sentence 2 UStG). If your customer is not established in Germany, the German mandate does not apply either (section 14.1(6) UStAE, German). Whether your customer's country has its own rules is a separate question.
How to prepare
Two steps make sense right away: make sure you can receive and read e-invoices, and plan the switch for sending well before your deadline. Rechnungskit automatically creates an e-invoice in ZUGFeRD 2.5 format from your payment and order data, validates it against EN 16931 and archives it in a tamper-proof way that meets GoBD, the German rules for electronic bookkeeping and records. That covers sending. Rechnungskit does not receive or read incoming invoices; for those, use your accounting software or the process your tax advisor recommends. The page on e-invoicing in Germany for online shops, SaaS and digital products shows the three typical setups and how payment providers connect, and the articles on Shopify and Stripe explain what those providers do on their own.
FAQ
- [1] § 14 UStG, German VAT Act (German)
- [2] § 27(38) UStG, transition rules for e-invoicing (German)
- [3] §§ 33, 34 and 34a UStDV: small amounts, tickets, small businesses (German)
- [4] BMF circular of 15.10.2025 on mandatory e-invoicing (German)
- [5] VAT Application Decree (UStAE), section 14.1, current version (German)
- [6] Federal Ministry of Finance (BMF): FAQ on mandatory e-invoicing (German)
- [7] IHK Frankfurt am Main: E-Rechnungspflicht ab 2025 (German)
- [8] DATEV: Gesetzliche Regelungen zur E-Rechnung (German)
Rechnungskit is not a tax advisory or law firm. This article explains general principles and does not replace advice from a tax advisor (Steuerberater, § 5 StBerG) or a lawyer (§ 3 RDG). Rechnungskit is built for businesses based in Germany and prepares documents, tax rates and bookings automatically. How your specific case is treated remains your decision, ideally together with your tax advisor or a lawyer.
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