E-invoicing mandate 2025–2028

The legal basis

The Wachstumschancengesetz (promulgated in March 2024) anchored the mandatory e-invoice for domestic B2B transactions in §14 UStG. Since then, an e-invoice is legally defined as an invoice in a structured electronic format compliant with EN 16931 that enables electronic processing — in practice XRechnung or ZUGFeRD (from the EN 16931 profile onwards).

Important: paper and simple PDF lose their precedence. The recipient's consent is no longer required for e-invoices — conversely, during the transition period the sender of other formats needs the recipient's consent.

What is often overlooked

• The obligation to receive has no transition period. Since 01.01.2025 any supplier may send you an XRechnung — and you cannot refuse it.
• Kleinunternehmer (§19 UStG) must be able to receive; relaxed rules apply to their own issuing.
• Domestic B2B transactions are affected — B2C and many cross-border cases are (still) exempt; the EU is working on the next stage with ViDA.
• Retention: the XML you receive is the original and must be retained tamper-proof for 8 years — an email folder is not enough.

Exemptions and special cases

• Kleinbetragsrechnung up to €250 (§33 UStDV) and transport tickets are exempt from the e-invoicing mandate — but may still be issued electronically.
• B2C transactions (to end consumers) are not covered; here PDF/paper remains permitted.
• Tax-exempt transactions under §4 Nr. 8–29 UStG (e.g. financial, medical-treatment and rental transactions) are exempt.
• Cross-border invoices to non-residents do not fall under the German mandate — but the EU is planning the next stage with ViDA.
• Kleinunternehmer (§19): obligation to receive yes; relaxed rules apply to issuing (an other-format invoice remains permitted).

What happens if you ignore it?

There is no dedicated 'e-invoicing fine' — the risks are more indirect and more expensive: an invoice that fails the formal requirements is not a proper invoice. On the recipient's side the input-VAT deduction is at risk, which is why large customers increasingly reject non-compliant documents; on the issuer's side there is the threat of late payment, correction effort and, in the event of an audit, disputes over the GoBD compliance of the entire process. Anyone who waits until 2028 risks switching over under time pressure — with all the errors that haste produces.

Your checklist

1. Define how you receiveSet up an inbox/upload and communicate it internally — the obligation already applies.
2. Ensure processingOrganise validation, rendering into a readable view and archiving of the XML documents (exactly what CoolHanX automates).
3. Test your own issuingFormats, mandatory fields, VAT logic — before the key date, not after.
4. Clarify handover to your tax advisorDATEV/CSV instead of document copies — saves effort on both sides.
5. Inform suppliers & customersExchange the electronic invoicing address (email/electronic address, BT-49).

Frequently asked questions

Where the mandate comes from — the Wachstumschancengesetz

The basis is the Wachstumschancengesetz (promulgated in March 2024), which redrafted §14 UStG. Since then, the e-invoice for domestic B2B transactions is legally defined as an invoice in a structured electronic format compliant with EN 16931. A PDF, a scan or a photo has since counted as an 'other invoice' — not as an e-invoice. The Federal Ministry of Finance has set out the application in more detail in a BMF letter.

Receiving is already mandatory — even without issuing yourself

The most important, often overlooked point: the obligation to receive has applied since 1 January 2025 with no transition period and no exception — including for Kleinunternehmer. Every domestic business must be able to accept, validate and retain structured e-invoices in a GoBD-compliant way. An email inbox is not enough for this: the XML must be archived in a processable form. Anyone who only plans to 'issue later' misses that receiving must already be handled today.

What you should concretely do now

1. Ensure you can receive — set up a way to receive, validate and archive XRechnung/ZUGFeRD (the Free plan covers this). 2. Prepare master data — record your own USt-IdNr and bank details, and for customers the electronic address (BT-49) or Leitweg-ID. 3. Test issuing — generate your first XRechnung to yourself or via the free validator before the key date presses. That way the transition is a changeover of weeks, not a year-end emergency.

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