Germany's 2025 e-invoicing mandate: what applies from January 1

In a nutshell

Since 1 January 2025, every company resident in Germany must be able to receive electronic invoices in B2B. The rule applies to every legal form — GmbH, AG, sole trader, freelancer — as soon as the recipient is also based in Germany.

The mandate is based on the Wachstumschancengesetz and § 14 UStG in the version applicable from 2025.

Who is affected?

• All domestic B2B transactions between companies resident in Germany
• No size-based exemption on the receiving side
• Not affected: invoices to private consumers (B2C) and to recipients outside Germany

Timeline

Date	What applies
01 Jan 2025	Every German company must be able to receive e-invoices
31 Dec 2025	End of the first transition period: paper and PDF invoices may still be sent (only with the recipient’s consent)
31 Dec 2026	End of the second transition period for companies with prior-year revenue up to €800,000
01 Jan 2027	Sending obligation for companies with > €800,000 prior-year revenue
01 Jan 2028	Full sending obligation for all B2B transactions

What counts as an “e-invoice” under the new definition?

From 2025 an e-invoice is only a document that

1. is issued in a structured electronic format,
2. complies with the European standard EN 16931,
3. allows electronic processing of the invoice data.

No longer sufficient: a plain PDF by email. From 2025 that counts as an “other invoice” — permitted only while the recipient consents and the transition period is running.

Permitted formats

Three formats meet the criteria without reservation:

• XRechnung — pure XML, the German CIUS of EN 16931
• ZUGFeRD 2.x (from profile EN16931 or XRECHNUNG) — hybrid PDF/A-3 with embedded XML
• Peppol BIS Billing 3.0 — UBL XML on the Peppol network

Not permitted: ZUGFeRD 1.0, ZUGFeRD profiles MINIMUM and BASIC WL (they lack some mandatory EN 16931 fields).

Mandatory fields in the XML structure

A valid e-invoice carries — in addition to the classic obligations under § 14 UStG — these EN 16931 fields:

• BT-1 invoice number
• BT-2 invoice date
• BT-3 invoice type (380 = invoice, 381 = credit note)
• BT-31 / BT-48 VAT IDs of issuer and recipient (if applicable)
• BT-112 invoice total amount with VAT
• BG-22 totals block (net, gross, taxes)
• BG-25 invoice lines with BT-126 through BT-141

For B2G, the Leitweg-ID (BT-10) remains mandatory on top.

Archiving obligation

E-invoices must be archived in their original format — not as a printout, not as a screenshot, but the structured XML or ZUGFeRD PDF itself. GoBD additionally requires:

• Immutability (no after-the-fact editing)
• Legibility across the full retention period (10 years per § 147 AO)
• Machine readability

PDF/A-3 satisfies the legibility requirement automatically — pure XRechnung XML must be kept unchanged organisationally or technically.

Technical implementation

What a company needs in 2025:

1. Receiving endpoint — typically an email address like invoices@company.de or a Peppol Access Point
2. Parser — able to read XRechnung/ZUGFeRD and feed the data into accounting
3. Archive system — GoBD-compliant, retention at least 10 years
4. Fallback channel — for foreign or non-compliant senders, as long as still permitted

Implementing with the Dokmatiq API

The Dokmatiq API covers the three critical steps:

# 1) Issue an e-invoice (XRechnung or ZUGFeRD)
curl -X POST https://api.dokmatiq.com/v1/einvoice/zugferd \
  -H "Authorization: Bearer $DOKMATIQ_KEY" \
  -d '{ "profile": "EN16931", "invoice": { ... } }'

# 2) Validate and parse an incoming e-invoice
curl -X POST https://api.dokmatiq.com/v1/einvoice/parse \
  -H "Authorization: Bearer $DOKMATIQ_KEY" \
  --data-binary "@incoming.xml"

# 3) Produce an archive-grade PDF/A-3
curl -X POST https://api.dokmatiq.com/v1/pdf/convert \
  -H "X-Target-Profile: PDF/A-3b" \
  --data-binary "@invoice.pdf"

Frequent misconceptions

1. “We don’t need anything until 2027” — wrong. Receiving has been mandatory since 2025. 2027/2028 only concerns sending.
2. “PDF is fine” — not any more. Plain PDF invoices are only allowed as “other invoices” from 2025 and require recipient consent.
3. “Peppol is optional” — Peppol is a transport channel, not a mandate. Email with an XRechnung attachment is enough.
4. “We’re too small” — the receiving obligation applies regardless of company size.