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Regulation2025-02-208 min readby TaxLayer Team

E-Invoice Mandate 2025: What Companies Need to Know Now

With the Growth Opportunities Act (Wachstumschancengesetz), the German parliament enacted the phased introduction of the e-invoice mandate for B2B transactions. Since January 1, 2025, all companies in Germany — from freelancers to corporations — must be able to receive structured e-invoices. Sending follows in stages starting in 2027.

> Quick answer: Since January 1, 2025, the receiving obligation for e-invoices applies to all companies. The sending obligation follows from January 1, 2027 (revenue > €800,000) or January 1, 2028 (all). Approved formats are ZUGFeRD and XRechnung per EN 16931.

What has been in effect since January 1, 2025?

Receiving obligation for all companies

Since January 1, 2025, every company must be able to receive and process e-invoices. A simple PDF invoice by email is no longer sufficient — the recipient must accept machine-readable formats such as ZUGFeRD, Factur-X, or XRechnung.

When does the sending obligation begin?

From January 1, 2027: Sending obligation (Phase 1)

Companies with annual revenue exceeding €800,000 must actively send e-invoices. Paper invoices and simple PDFs will no longer be permitted. More details: E-Invoice Mandate 2027.

From January 1, 2028: Sending obligation (Phase 2)

The sending obligation applies to all companies, regardless of revenue. Small businesses must then also send e-invoices.

What qualifies as an e-invoice under the Growth Opportunities Act?

An e-invoice must comply with the European standard EN 16931. The following formats are accepted:

  • ZUGFeRD 2.1 / 2.2 (profile EN 16931 or higher)
  • Factur-X (identical to ZUGFeRD)
  • XRechnung (UBL or CII)

Not considered e-invoices:

  • Simple PDF files
  • Scanned paper invoices
  • Image files (JPEG, TIFF)

Which fields a valid e-invoice must contain is explained in our article EN 16931: All Required Fields.

What do you need to do now?

  1. Receive e-invoices: Ensure your accounting software can open and process ZUGFeRD/XRechnung files
  2. Prepare for sending: Check whether your invoicing software can generate e-invoices
  3. Use a transitional solution: TaxLayer automatically converts your existing PDF invoices to ZUGFeRD format
  4. Adapt processes: Inform your accounting department about the new requirements

What penalties apply for non-compliance with the e-invoice mandate?

The Federal Ministry of Finance has not yet announced specific fines. However, non-compliant invoices may not be recognized for tax purposes, which can lead to problems with input tax deduction. Companies should therefore not delay the transition.

How can I validate my e-invoices before sending?

Check your e-invoices before sending with the free ZUGFeRD & XRechnung Validator. Or create an XRechnung directly via the XRechnung Generator — no registration required.

TaxLayer automatically converts your existing PDF invoices into validated e-invoices — the first two conversions per month are free, no credit card required.

Frequently asked questions

What changed on January 1, 2025 regarding e-invoicing?

Since January 1, 2025, all companies in Germany must be able to receive and process e-invoices in ZUGFeRD or XRechnung format. A simple PDF is no longer sufficient.

When do I have to start sending e-invoices?

From January 1, 2027 for companies with prior-year revenue exceeding €800,000. From January 1, 2028 for all companies. Details: E-Invoice Mandate 2027.

Which formats qualify as e-invoices?

Only formats that comply with EN 16931: ZUGFeRD 2.x (from profile EN 16931), Factur-X, and XRechnung. Simple PDFs, scans, and image files do not qualify as e-invoices. Overview: EN 16931 Required Fields.

Am I affected as a small business owner?

Yes. The receiving obligation has applied without exception since 2025. The sending obligation for small businesses takes effect in 2028. All details: Small Business & E-Invoicing.

Are there penalties for non-compliance?

There are no specific fines so far. However, non-compliant invoices may not be recognized for tax purposes, which jeopardizes the recipient's input tax deduction.

How can I convert my invoices quickly?

With TaxLayer, you can automatically convert existing PDF invoices to ZUGFeRD or XRechnung format. No software switch needed, the first 2 conversions per month are free.

Convert PDF invoices now

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