Invoicing compliance in Germany

Comprehensive guide to Germany’s mandatory e-invoicing requirements, XRechnung and ZUGFeRD implementation, and upcoming e-reporting obligations for B2B and B2G transactions

Germany's e-invoicing regulation timeline

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🇩🇪 Germany related resources

Compliance	🇩🇪  Invoicing compliance in Germany Compliance timeline
Apps	OASIS UBL ZUGFeRD
Guides	XRechnung Guide ZUGFeRD Guide
FAQ	Germany FAQ
GOBL	Germany Tax Regime German XRechnung Addon German ZUGFeRD Addon

Executive summary

Germany distinguishes clearly between B2G and B2B electronic invoicing. For B2G, the XRechnung format—based on EN 16931 and implemented in UBL or CII syntax—has been mandatory since November 2020 for all invoices to public authorities, typically exchanged via the Peppol network.

For B2B, businesses must be able to receive structured e-invoices compliant with EN 16931, while issuing such invoices will become mandatory from Jan 2027 for companies with turnover above €800.000, and from January 2028 for all businesses in domestic B2B transactions. ZUGFeRD, a hybrid PDF + XML format aligned with EN 16931 and equivalent to France’s Factur-X, is accepted alongside XRechnung.

Germany is preparing for EU-wide Digital Reporting Requirements (ViDA), expected around 2030, which will introduce VAT e-reporting requirements based on EN 16931 data.

Structured invoices must be archived in their original XML format for eight years, in compliance with GoBD rules ensuring data integrity, readability, and domestic accessibility.

Invopop provides coverage for German invoicing through the OASIS UBL and ZUGFeRD apps, supporting both XRechnung and ZUGFeRD formats. The platform also offers integrations with Stripe and Chargebee, enabling businesses to issue compliant invoices directly from their merchant or ERP platforms while automatically handling format compliance and Peppol network routing when required.

Invoicing in Germany

Electronic invoicing is well established and regulated, with a clear distinction between B2G and B2B/B2C transactions. For B2G, the XRechnung format is mandatory for invoices to public authorities, and these are primarily exchanged via the Peppol network or authorized access points. B2B and B2C invoicing remain largely unregulated in format, though adoption of e-invoicing standards is increasing, especially for efficiency and integration with accounting systems.

Under the recently passed Wachstumschancengesetz (Growth Opportunities Act), Germany will implement a phased rollout for domestic B2B invoicing in structured electronic formats. For more information, check the ZUGFeRD section below.

XRechnung (B2G)

XRechnung is Germany’s standard for e-invoices in public procurement (B2G, called E-Rechnungen), though it can also be used for B2B transactions. It’s part of the implementation of the EU directive 2014/55/EU, which requires all contracting authorities in the EU to accept electronic invoices in a structured XML file. It can be implemented using two different syntaxes, CII and UBL.

Models	B2G (primary use) or B2B
Format	OASIS UBL and UN/CEFACT CII
Infrastructure	Peppol
Model	Hybrid
Scope & Deadline	B2G Since Nov. 2020
Agency	BMI
Invopop Support	OASIS UBL UN/CEFACT CII

ZUGFeRD (B2B)

ZUGFeRD is a German standard for electronic invoicing designed to bridge the gap between traditional invoices and digital formats. ZUGFeRD combines a standard PDF/A-3 invoice with an embedded XML file containing the structured data. This hybrid approach is well suited for B2B transactions, as it allows both people and accounting software to work with the same document. It is fully aligned with the European Norm EN 16931. It is worth noting that ZUGFeRD and Factur-X are a joint project between Germany and France, and their content is identical.

Models	B2G (primary use) or B2B
Format	OASIS UBL and UN/CEFACT CII
Infrastructure	Peppol
Model	Hybrid
Scope & Deadline	B2G Since Nov. 2020
Agency	BMI
Invopop Support	OASIS UBL UN/CEFACT CII

E-reporting

Germany is aligning with the EU’s ViDA directive, which projects Digital Reporting Requirements (DRRs). Digital reporting obligation is likely around 2030 or later for Germany, though exact timelines and legal details are not yet fixed. The forthcoming reporting model would require EN 16931 compliant data enabling tax authorities to access invoice‑level data for VAT monitoring and fraud prevention.

Regulation

Archival requirements

In July 2025, the Ministry of Finance made public how structured e-invoices must be archived:

• Only the XML must be archived (even if it’s a ZUGFeRD hybrid) the embedded XML is the tax‑binding element. PDFs are optional if a readable view can be generated.
• Invoices must be stored in the XML format received (CII or UBL), even if converted internally, to satisfy audit requirements.
• Data generally must remain in Germany and must comply with GoBD.
• Germany shortened the invoice archival period from 10 to 8 years.

Other requirements

Germany’s e‑invoicing compliance is strict and technical, especially around invoice content, format, and archiving:

• Legally required invoice elements: seller/buyer tax IDs, invoice number, date, line‑item details, VAT breakdowns, and references to contracts or purchase orders if applicable. Missing or incorrect data can make an invoice legally invalid.
• Structured formats: For B2G, this is XRechnung; for future B2B mandates, invoices will need to be EN 16931-compliant (XRechnung or ZUGFeRD). PDFs without an XML attachment are insufficient for mandated channels.
• Archiving: All invoices, whether received or issued, must be retained digitally and unaltered for 8 years in a compliant system.

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