Reference · Germany

Germany's B2B e-invoicing mandate: XRechnung, ZUGFeRD and the 2027/2028 dates

Receiving a structured invoice has been mandatory for every domestic B2B transaction since 1 January 2025. Issuing one is phased in over two more years, on a date set by your own turnover.

The mandate's legal basis is the Wachstumschancengesetz of 27 March 2024 (BGBl. 2024 I Nr. 108), which rewrote § 14 UStG to define an E-Rechnung as a structured format enabling automated processing, and inserted the transitional timetable into § 27 Abs. 38 UStG. That calendar has not moved since — Germany's dates are the stable ones among the European mandates.

The issuing side, in two steps

Issuing is where the phase-in actually happens, and it runs in two steps rather than one. For supplies made after 31 December 2024, an invoice may still be issued on paper, or electronically in a non-compliant format with the recipient's consent, until 31 December 2026, available to any issuer regardless of size.

For supplies made after 31 December 2026, that relief continues for one more year, to 31 December 2027, but only for an issuer whose total turnover (Gesamtumsatz) in the preceding calendar year did not exceed €800,000. The BMF letter of 15 October 2025 states the test as turnover in calendar year 2026. EDI under Commission Recommendation 94/820/EC remains permissible on the same schedule, until 31 December 2027, with the recipient's consent. The net effect is a hard issuing obligation from 1 January 2027 above €800,000 in prior-year turnover, and from 1 January 2028 for everyone else.

Outside these rules entirely are supplies exempt under § 4 Nr. 8–29 UStG, small-amount invoices up to €250 under § 33 UStDV, and travel tickets under § 34 UStDV. None of these are brought into scope by the mandate.

XRechnung, the pure-XML format

XRechnung is a pure-XML CIUS of EN 16931 — a Core Invoice Usage Specification that restricts the European standard rather than extending it. The BMF letter of 15 October 2025 describes it as a rein strukturiertes Format that corresponds to EN 16931 and satisfies § 14 Abs. 1 Satz 6 Nr. 1 UStG. Alongside its compliant core data model it also defines a conformant Extension XRechnung, and the standard supports both the UBL and the CII syntaxes. The version in force is 3.0.2 (KoSIT / XStandards Einkauf, bundle 2026-01-31); version 4.0, announced for mid-to-late 2026, is planned to implement a 2026 edition of EN 16931 and rework the underlying data model, but it is not released yet.

ZUGFeRD, the hybrid format

ZUGFeRD is a hybrid PDF/A-3 format (a structured XML part and a human-readable PDF part in one file), and it is technically identical to Factur-X. The current release, ZUGFeRD 2.4 / Factur-X 1.08 (FeRD and FNFE-MPE, 4 December 2025, in force 15 January 2026), is based on UN/CEFACT CII D22B and stays fully backward compatible with D16B, with each of its five profiles carrying its own XSD and Schematron.

Germany does not require XRechnung specifically

Which admissible format two parties use is, per the same BMF letter, a civil-law question they decide between themselves. It is not a tax-authority requirement. The permitted formats are not limited to national ones, provided they conform to EN 16931. XRechnung is the format German public-sector procurement has standardised on, but nothing in the B2B mandate forces a supplier to send XRechnung rather than an EN 16931-compliant ZUGFeRD, or any other conformant format the recipient will accept.

What this does not cover

EUInvoice does not produce ZUGFeRD or XRechnung output and does not transmit invoices. This article covers only the domestic B2B mandate under § 14 UStG; it does not cover the German B2G channel (federal and state e-invoicing portals for invoices to public bodies) or e-reporting, which are separate obligations with their own rules.