E-Invoicing in Germany
B2B e-invoicing under the Growth Opportunities Act, EN 16931, ZUGFeRD and XRechnung
The mandate at a glance
Germany runs the largest e-invoicing transition in Europe by business count. The Growth Opportunities Act (Wachstumschancengesetz) made structured e-invoice reception mandatory for every VAT-registered business in January 2025, and phases in the issuing obligation through 2027 and 2028. A PDF sent by email stopped being a legally privileged invoice format the moment the reception rule took effect: the structured XML is now the legally decisive layer.
The mandate is format-open but standard-strict: any format compliant with EN 16931 is acceptable. In practice the German market has settled on two: ZUGFeRD, a hybrid PDF/A-3 with embedded CII XML that keeps invoices human-readable, and XRechnung, the pure-XML national CIUS required in the public sector.
| Date | Obligation | Scope |
|---|---|---|
| January 2025 | Must be able to receive structured e-invoices | All VAT-registered businesses |
| January 2027 | Must issue structured e-invoices | Businesses with turnover above EUR 800,000 |
| January 2028 | Must issue structured e-invoices | All VAT-registered businesses |
Required formats and network
Accepted formats: any EN 16931-compliant syntax. ZUGFeRD (profiles EN 16931 and EXTENDED are the safe B2B choices) dominates because accounts-payable teams can still open the PDF, while DATEV, SAP, and Lexware import the embedded XML. XRechnung, in either CII or UBL syntax, is equally valid for B2B and mandatory for B2G.
There is no clearance platform: invoices travel directly between trading partners (by email, portal, or Peppol), which keeps integration simpler than in Italy or Poland but puts the full validation burden on the sender and receiver.
Public sector (B2G)
XRechnung has been mandatory for invoices to German federal authorities since November 2020, submitted via Peppol, ZRE, or OZG-RE portals. Every B2G invoice must carry a Leitweg-ID, the buyer routing identifier, in the BuyerReference field; a missing or malformed Leitweg-ID is the single most common rejection cause.
How to comply
- Confirm your systems can ingest structured e-invoices (ZUGFeRD and XRechnung) today: the reception duty already applies.
- Pick your issuing format: ZUGFeRD where humans still read invoices, XRechnung for public-sector buyers.
- Validate every outgoing invoice against the EN 16931 rule set plus the German CIUS rules before sending.
- Capture the Leitweg-ID for public-sector buyers and map it to BuyerReference.
- Plan for the January 2027 issuing deadline now if your turnover exceeds EUR 800,000.
What InvoiceXML supports for Germany
Frequently asked questions
Is a PDF invoice still legal in Germany?
A plain PDF no longer counts as an e-invoice under German VAT law. Since January 2025 the structured XML data is the legally decisive invoice. During the transition, senders may still issue paper or plain PDF with the recipient's consent, but that option ends with the issuing phases in 2027 and 2028.
ZUGFeRD or XRechnung: which one do I need?
For B2B either works, and ZUGFeRD is usually preferred because the PDF layer stays human-readable. For invoices to German public-sector buyers, XRechnung is mandatory. Both satisfy EN 16931, and the embedded ZUGFeRD XML at the EN 16931 profile is technically an XRechnung-compatible CII document.
Does Germany require a government clearance platform?
No. Unlike Italy's SDI or Poland's KSeF, Germany has no central clearance. Invoices are exchanged directly between the parties, and each side is responsible for validating conformance.
What is a Leitweg-ID and when do I need one?
The Leitweg-ID is the routing identifier German public-sector buyers assign for B2G invoices. It goes in the BuyerReference field of an XRechnung. It is required for every invoice to a federal, state, or municipal authority, and is not used in B2B.
E-Invoicing in France →
E-Invoicing in Belgium →
E-Invoicing in Poland →