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E-Invoice: Everything About Electronic Invoicing from 2025

From 1 January 2025, mandatory e-invoicing applies across Germany: this was enacted by the Bundestag as part of the Growth Opportunities Act (Wachstumschancengesetz) 2023.

From 1 January 2025, mandatory e-invoicing applies across Germany: this was enacted by the Bundestag as part of the Growth Opportunities Act (Wachstumschancengesetz) 2023. Going forward, businesses must issue e-invoices to other businesses; this obligation applies exclusively to B2B transactions.

How am I supposed to implement e-invoicing so quickly? This is the question many business owners ask when they first encounter the topic. There is no need to panic: the legislature has provided generous transitional arrangements. From the turn of 2024/2025, only the receipt of e-invoices is mandatory — and you will have no difficulty meeting this requirement.

Nevertheless, it is worth familiarising yourself with e-invoicing and its implementation at an early stage. These structured invoice formats can be processed automatically, reducing the workload in accounting and bookkeeping.

The term e-invoice is widely used: many people apply it to all electronic invoices such as emails and PDF documents. However, this is not what the legislature means — the term refers to a structured, XML-based data format. In Germany, for example, the XRechnung format qualifies as an e-invoice within the meaning of the e-invoicing obligation.

In concrete terms, an e-invoice means:

- The XML format contains all relevant data in a structured form.

- This data can be read and processed automatically.

- The format complies with European standard EN 16931.

All other invoices are referred to by the legislature as "other invoices". These include paper invoices, image files (scanned invoices), and PDF documents.

The obligation to issue and receive e-invoices applies to all businesses that generate revenue with other businesses. Furthermore, the obligation applies exclusively to companies based in Germany.

On closer examination, the e-invoicing obligation is considerably reduced in scope, as there are several relevant exceptions:

- Invoices to end consumers are not subject to the e-invoicing obligation. Businesses may continue to issue other types of invoices.

- The e-invoice is not mandatory for small businesses (Kleinunternehmer) either. They retain flexibility when issuing invoices, but must be able to receive e-invoices.

- For all small amounts with a gross value of up to 250 euros, businesses are not required to issue an e-invoice.

- Exemptions also exist for various VAT-exempt supplies.

Want to make sure whether you are required to issue an e-invoice? Ask the experienced tax professionals at Guhr Steuerberatung!

The e-invoicing obligation comes into force on 1 January 2025, but in practice little will change at that point. This is due to generous transitional arrangements that give businesses sufficient time to adapt. From 2025, only the receipt of invoices in an appropriate format is mandatory.

During the period from 1 January 2025 to 31 December 2026, invoice issuers are free to choose which format they use. They may switch to e-invoices or continue to send other types of invoices, such as a paper invoice or a PDF invoice.

However, savvy business owners should switch to e-invoicing as soon as possible. This avoids time pressure later as the turn of 2026/2027 approaches. E-invoices also offer a wide range of advantages, such as the ability to extract and process data automatically.

From the start of 2025 you must be able to receive e-invoices. Bear in mind that from this point any other business may voluntarily issue you an e-invoice. Previously, companies required the recipient's consent before sending one; this consent requirement is being removed. This means that from 1 January you may find yourself receiving e-invoices.

The good news is: an email inbox is sufficient to fulfil the statutory obligation. It is enough for the invoice issuer to be able to send you the invoice format by email.

Do make sure, however, that you can read and process the corresponding e-invoices. If in doubt, ask your Guhr Steuerberatung!

As a first step, choose an invoice format that meets the statutory criteria for an e-invoice. In Germany, these two formats in particular have become established:

- XRechnung

- ZUGFeRD from version 2.0.1

In addition, invoice issuers and recipients may use other formats, provided they agree on this and the format complies with the statutory requirements.

Creating and processing these invoice formats can be achieved through a variety of means. Do you use invoicing software? Paid solutions in particular tend to include the relevant extensions. Alternatively, you can use various add-ons, apps, or online generators.

When transmitting e-invoices you benefit from considerable flexibility. You can send the e-invoice by email, for example, or make it available for download via a customer portal. Various types of electronic interfaces are also suitable for transmission. The legislature also accepts delivery on data carriers such as a USB stick.

Do you have further questions about e-invoicing? Or would you like to outsource the associated bookkeeping challenges? Contact your Guhr Steuerberatung!

How does e-invoicing work?

An e-invoice within the meaning of the legislation contains structured data in an XML-based format. This distinguishes it from paper invoices and electronic formats such as a PDF invoice document. Businesses must in future issue invoices in an accepted format such as XRechnung, and recipients must be able to read and process this format. The change relates solely to the form of the invoice; the mandatory content of invoices remains unchanged.

Who must issue e-invoices from 2025?

From 2025, there is only an obligation to receive e-invoices. Invoice issuers benefit from transitional arrangements until 31 December 2026. From that point, the obligation applies to B2B transactions unless an exception applies. Exceptions to e-invoicing exist, for example, for small amounts up to 250 euros gross and for various VAT-exempt supplies. There is no e-invoicing obligation for invoices to end consumers.

Will e-invoicing become mandatory?

Mandatory e-invoicing for domestic businesses has been enacted. From 2025, the obligation to receive e-invoices applies. Invoice issuers may freely choose until the end of 2026 whether to send an e-invoice or another type of invoice. From 2027 at the latest, e-invoicing is mandatory for the vast majority of B2B transactions where the gross invoice amount exceeds 250 euros. Small businesses (Kleinunternehmer) are exempt from the e-invoicing requirement.

Which software for e-invoices?

High-quality accounting software packages include the ability to create, read, and process e-invoices. In that case, your workload is minimal — with just a few clicks you can convert your invoice data into the XRechnung format, for example. Are you planning to acquire invoicing software in the near future? Check the e-invoicing features! There are further options such as add-ons or online generators.

What counts as an e-invoice from 2025?
An e-invoice within the meaning of the legislation is a structured, XML-based data format that complies with European standard EN 16931 and can be read and processed automatically. In Germany, the formats XRechnung and ZUGFeRD from version 2.0.1 in particular have become established. Paper invoices, scanned image files, and PDF documents, by contrast, only count as "other invoices".
Who must issue e-invoices, and from when?
From 1 January 2025, only the receipt of e-invoices is initially mandatory. During the period from 1 January 2025 to 31 December 2026, invoice issuers may freely choose whether to send e-invoices or other invoices such as paper or PDF. From 2027 at the latest, e-invoicing is mandatory for the vast majority of B2B transactions between businesses based in Germany, unless an exception applies.
What exceptions are there to the e-invoicing obligation?
Invoices to end consumers are not subject to the e-invoicing obligation. Small businesses (Kleinunternehmer) are also not required to issue e-invoices, although they must be able to receive them. In addition, small amounts up to 250 euros gross are exempt, and exemptions also exist for various VAT-exempt supplies.
What do I need in order to receive e-invoices from 2025?
An email inbox through which invoice issuers can send you the format is sufficient to fulfil the statutory receipt obligation. Bear in mind that from 2025 any business may send you e-invoices without your consent, as the previous consent requirement is being removed. You should therefore make sure you can also read and process incoming e-invoices, for example via your invoicing software or suitable add-ons.

About the author

Karsten Guhr · Managing Director & Tax Advisor

Founder of the firm. Advising entrepreneurs and holding structures on tax planning, structuring and succession for 15+ years.

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