Germany · e-invoicing · Partly in force

Germany e-invoicing obligations

Germany imposes 2 separate filing obligations under e-invoicing. The earliest is E-Rechnung — Empfang, due In force since 1 January 2025. Checked against the authority on 4 October 2026.

Checked 4 October 2026 Primary-sourced 2 separate filing obligations

Receiving has been compulsory since January 2025. Issuing starts 2027 — and uniquely, there is no portal and no accreditation.

Germany also has obligations under Pillar Two. See the Pillar Two page →

Access gate — clear this before anything can be filed

None — no portal, no accreditation

Germany deliberately built no central platform. The BMF states the law prescribes no particular channel: email, an electronic interface, shared storage or a portal all qualify. The lightest regime in Europe to connect to.

What is in force in Germany

ChargeLocal nameIn force from
ReceiveE-Rechnung (Empfangspflicht)1 January 2025 — all domestic businesses
IssueE-Rechnung (Ausstellungspflicht)1 January 2027 if prior-year turnover above EUR 800,000; 1 January 2028 for the rest

The 2 separate filing obligations

E-Rechnung — Empfang

Also: receiving obligation

Ability to receive a structured electronic invoice from any domestic supplier.

Who files
Every domestic business (inländische Unternehmer). An email inbox is sufficient.
Deadline
In force since 1 January 2025
Channel
Any — no prescribed route

FAQ E-Rechnung — Bundesfinanzministerium ↗

E-Rechnung — Ausstellung

Also: issuing obligation

Issue domestic B2B invoices in a structured format compliant with EN 16931.

Who files
Businesses with prior-year turnover above EUR 800,000 from 2027; all others from 2028. Invoices under EUR 250 and B2C are out of scope.
Deadline
1 January 2027 (turnover above EUR 800,000); 1 January 2028 (all others)
Channel
XRechnung or ZUGFeRD 2.0.1+ (excluding MINIMUM and BASIC-WL). EDI permitted transitionally to end-2027.

FAQ E-Rechnung — Bundesfinanzministerium ↗

Penalties

Up to EUR 5,000 as an administrative offence under § 26a(2) UStG for failure to issue correctly or on time; up to EUR 1,000 for retention breaches. Commercially the larger exposure is input-VAT recovery on non-compliant invoices.

What catches groups out in Germany

  • Receiving has been mandatory since January 2025 — many groups still have no structured inbox.
  • The structured XML is the leading version in a hybrid invoice, not the PDF.
  • The operative guidance is the second BMF-Schreiben of 15 October 2025.

Recent changes affecting Germany

  • 2026-09-17 — BZSt reports the OECD's 11 September 2026 updated GIR template, applying to fiscal years beginning on or after 31 December 2025; the GIR XML schema is being revised.
  • 2026-08-31 — Rule 60022 found to generate incorrect FileErrors on UPE correction messages omitting the GeneralSection; 70053 to be deactivated and 70030 revised.
  • 2026-08-14 — Rules 70012 and 70037 added to the deactivated list; 70030 and 70053 under review. Acceptance requires Accepted status with no RecordError entries.
  • 2026-08-06 — Kommunikationshandbuch Mindeststeuer-Bericht v1.3 published; data set description v1.3 dated 5 June 2026.

All dated changes →

Common questions

What must be filed in Germany under e-invoicing?

2 separate obligations: E-Rechnung — Empfang; E-Rechnung — Ausstellung.

When is the E-Rechnung — Empfang due in Germany?

In force since 1 January 2025. Filed by: Every domestic business (inländische Unternehmer). An email inbox is sufficient.. Channel: Any — no prescribed route.

When is the E-Rechnung — Ausstellung due in Germany?

1 January 2027 (turnover above EUR 800,000); 1 January 2028 (all others). Filed by: Businesses with prior-year turnover above EUR 800,000 from 2027; all others from 2028. Invoices under EUR 250 and B2C are out of scope.. Channel: XRechnung or ZUGFeRD 2.0.1+ (excluding MINIMUM and BASIC-WL). EDI permitted transitionally to end-2027..

What access is needed before filing in Germany?

None — no portal, no accreditation. Germany deliberately built no central platform. The BMF states the law prescribes no particular channel: email, an electronic interface, shared storage or a portal all qualify. The lightest regime in Europe to connect to.

What are the penalties in Germany?

Up to EUR 5,000 as an administrative offence under § 26a(2) UStG for failure to issue correctly or on time; up to EUR 1,000 for retention breaches. Commercially the larger exposure is input-VAT recovery on non-compliant invoices.

Where this comes from

Every row on this page was checked against the authority's own published page on 4 October 2026. Verified against the BMF FAQ and the BMF-Schreiben of 15 October 2025.

Cite this page

Saurabh Satija, “Germany e-invoicing filing obligations”, https://saurabhsatija.com/e-invoicing-germany, accessed [date].

Quotation and citation with attribution and a link are welcome. The underlying data is open as JSON and as plain text.

Other e-invoicing jurisdictions

France · Italy · Spain · Belgium · Poland · European Union — ViDA

All 21 entries in the tracker →

How many of these are actually yours?

This page shows what Germany requires. The scoping tool takes your whole footprint and returns every filing it triggers, in deadline order, with the access prerequisites attached. About thirty seconds.