Who has to issue e-invoices from 2025?

All businesses in Germany that have turnover with other domestic businesses have to issue e-invoices, with a few exceptions.

Which formats are accepted as an e-invoice?

In principle, e-invoice formats have to comply with the European standard. Those are invoices in the XRechnung format and ZUGFeRD from version 2.0.1 onwards.

How long is the transition period?

Until 31 December 2026 there is still no general obligation to use e-invoices, and sending them also has to be agreed with the recipient. In individual cases the transition period is extended by a further year.

E-invoicing from 2025: what German businesses must do

Germany wants to digitalize with the help of the e-invoice

From 1 January 2025, electronic invoices, known as e-invoices, must be used for turnover between domestic businesses (that is, as soon as the registered office, the management or a permanent establishment is in Germany). There are certain exceptions and transitional rules, but in the long term this law is meant to drive the digitalization of German bureaucracy.

The German federal government hopes that this measure will simplify processes in invoicing and invoice processing. With standardised e-invoices, for example, end consumers no longer have to have invoices recorded digitally and this saves duplicated work.

‍

This is what the new rules look like

The law does not only determine that e-invoices are now compulsory. It also sets standards and foundations to make nationwide consistency possible.

How the definition of the e-invoice changes

To understand the subject of e-invoices, we first have to look at the term more closely. Because with the new law, what we understand by an e-invoice changes too.

Up to now, e-invoices were invoices that were transmitted in an electronic format. That also included invoices in PDF form, for example. Turnover carried out up to 31 December 2024 may still be invoiced in this or in a non-electronic format.

From 1 January 2025, however, the PDF document no longer falls under the term e-invoice. It will instead be called an “other invoice”, together with non-electronic invoices.

The e-invoice from 1 January 2025

The new law defines an electronic invoice as a document in a structured electronic format. That means the invoice has to be issued, transmitted and processed electronically. A PDF does not fall under this definition for the simple reason that it cannot be processed electronically. The same applies to image files, for example.

Instead, e-invoices have to comply with the European standard. That means they have to be in one of the following formats:

XRechnung
ZUGFeRD from version 2.0.1 onwards (with the exception of the MINIMUM and BASIC-WL profiles)
EDI procedure (as long as this is agreed between the issuer and the recipient of the invoice)

This law does not only apply to the invoice issuer's side, though. The invoice recipient also has to make sure that they can receive e-invoices. A simple email inbox is enough for that. Processing the invoice onwards as an e-invoice is not compulsory. Put casually, the recipient can also print the e-invoice out if they want to.

Incidentally, e-invoices still have to be kept unchanged in their original form for at least eight years.

For cash purchases of more than €250, for example, e-invoices can also be created after the fact from an other invoice and sent to the recipient.

Who is not affected by the e-invoice?

In principle the law prescribes that from 1 January 2025 all turnover between domestic businesses has to be invoiced with e-invoices. There are exceptions, however.

No e-invoice has to be issued in the following cases:

private end consumers
where there is no VAT obligation to issue an invoice
small amounts of up to €250
travel tickets that count as an invoice
services provided by small businesses
services to legal persons that are not businesses
certain services to end consumers in connection with a property
invoices to public authorities (B2G) where they are not acting as a business
clubs and associations in non-commercial activity
cash purchases up to €250

‍

What do the transitional rules for the e-invoice look like?

Even though the law comes into force on 1 January 2025, there is no nationwide obligation to use e-invoices from that date. From 1 January 2025 until 31 December 2026, other invoices can still be created. This is meant to give businesses the chance to adapt to the changes within a reasonable period.

Where the invoice issuer had turnover of up to €800,000 in the previous year, the deadline is extended to 31 December 2027. The same applies to invoices in the EDI procedure that do not meet the European standard.

In addition, until 31 December 2026 e-invoices can only be created and sent once it has been made sure that the recipient can also receive them. Here too, recipients are to be given a period to adapt.

‍

An email inbox is enough to receive an e-invoice.

‍

E-invoices for hospitality businesses

Hospitality, the hotel industry and catering are affected by the e-invoice obligation too. However, the e-invoice does not apply to private end consumers. Even so, every hospitality business receives invoices from suppliers. So they also have to prepare for the e-invoice obligation. In practice this means that businesses working in the hospitality trade have to be able to receive e-invoices from 2027 at the latest.

‍

Several devices showing the interface of the clockin app. An iPhone on the left with the clockin home screen, an iPad in the middle with a revenue overview, customer information and a map, and another iPhone on the right with similar financial data. The app uses a clean design with red charts and map integration for a clear presentation of business information.

With clockin you create invoices simply and efficiently. Thanks to the integrations with Lexware Office and sevDesk, e-invoices are generated automatically. You record project hours conveniently through the clockin app. That data is then transferred straight to your accounting software – fully automatically and without errors.

Learn more here!

‍

Source: German Federal Ministry of Finance

‍