As of 12 September 2026. A German e-invoice is more than a PDF. Since 1 January 2025, Section 14 of the German VAT Act (UStG) defines it as an invoice in a structured electronic format that allows electronic processing. Transitional rules still apply to mandatory issuance in 2026.
This article explains public primary sources in general terms; it is not tax or legal advice. The actual service, issuer, recipient, type of supply and possible exceptions matter for each transaction.
What counts as an e-invoice in 2026?
The BMF FAQ of March 2026 says an e-invoice must be issued, transmitted and received in a structured electronic format suitable for electronic processing. A plain PDF is an “other invoice”; software would need OCR or individual interpretation to understand it. Calling a document a “PDF invoice” says nothing about whether it has the necessary structured data.
Which formats does the BMF identify?
- XRechnung: structured XML without its own PDF view.
- ZUGFeRD from version 2.0.1: a hybrid PDF with embedded XML, except the MINIMUM and BASIC-WL profiles.
Both can meet German VAT requirements. Technical validation can identify format and business-rule errors but does not guarantee tax acceptance. Rechnungstool creates finalised ZUGFeRD PDFs under EN 16931. The visible PDF is readable and the embedded data can be processed by software. See ZUGFeRD vs XRechnung.
Who is generally affected?
The BMF FAQ concerns supplies between businesses established in Germany. This may include freelancers, other self-employed people, landlords and small businesses. Private consumers are outside this B2B rule. A business is generally considered domestic if its registered office, management or participating fixed establishment is in Germany; residence or habitual abode may also matter. Cross-border work, tax-exempt supplies, public authorities and special types of supply can have different rules.
What applies to issuing invoices in 2026?
From 1 January 2025 to 31 December 2026, all issuers may still use the BMF transition rule to issue an “other invoice” instead of an e-invoice. Paper is possible; another electronic format such as a plain PDF generally needs recipient consent. For issuers with previous-year turnover up to €800,000, that period extends through 2027. Certain EDI methods that do not yet meet e-invoice requirements can also be used through 2027 under the stated conditions.
| Period | General position |
|---|---|
| 2025–2026 | All issuers may use the transition rule for other invoices. |
| 2027 | Extension for issuers with previous-year turnover up to €800,000 and certain EDI arrangements. |
| After the relevant transition period | Affected domestic B2B supplies generally require an e-invoice unless an exception applies. |
Recipients already need to handle e-invoices, and preparing master data, workflows and retention takes time.
Receipt has been required since 1 January 2025
Domestic businesses must be able to receive e-invoices. An email inbox is generally sufficient. This applies to small businesses too, even where they may be exempt from issuing them for their own supplies. Receipt does not require automatic import into complex accounting software, but the structured record must remain available and should be readable and reviewable.
Important exceptions
The rule does not apply to every document. The BMF lists invoices to private consumers; many tax-exempt supplies under Section 4 numbers 8–29 UStG; small-value invoices up to €250 gross; transport tickets that count as invoices; supplies by small businesses under the exemption; and certain supplies to non-business legal entities. Public authorities may have additional B2G rules. A Leitweg-ID is generally unnecessary in ordinary B2B invoices but may matter for government invoices.
What must be in the structured file?
All VAT-mandatory details belong in the structured part so they can be processed automatically. Merely pointing from XML to an unstructured attachment is insufficient for required information. In hybrid ZUGFeRD, the structured data takes precedence under BMF guidance if PDF and XML differ. Generate and check both from the same source.
Retention is a separate task
Section 14b UStG requires copies of incoming and outgoing invoices to be kept for eight years. At least the structured part of an e-invoice must remain intact in its original form. The BMF also refers to the German GoBD recordkeeping rules. Software can support retention, but does not automatically make every process compliant. Organisation, access rights, changes, exports, backups and procedure documentation matter too.
A practical checklist
- Classify your supplies as B2B, B2C, B2G or exempt.
- Make sure you can receive and read e-invoices.
- Decide whether to issue ZUGFeRD or XRechnung already in 2026.
- Keep sender, customer, item, tax rate and service-period data structured.
- Separate editable drafts from finalised invoices.
- Check structured data and retain the original format.
- Ask a tax or legal adviser about special cases.
Primary sources
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