By the yourtinyoffice team · Published 29/10/2026 · updated 30/10/2026

Germany's e-invoicing mandate 2025, 2027, 2028: what freelancers have to do

The next step comes on 1 January 2027: if your turnover in 2026 was above €800,000, invoices to other German businesses must then be e-invoices. From 1 January 2028 that applies to every business, small businesses under § 19 UStG excepted. Receiving e-invoices has been required since 1 January 2025, freelancers included, and until the end of 2026 everyone may still send paper or PDF invoices.

What has applied since 1 January 2025?

The Wachstumschancengesetz of 27 March 2024 rewrote the invoice rules in § 14 of the German VAT Act (UStG). Since 1 January 2025 the law knows two kinds of invoice. An e-invoice is issued, sent and received in a structured electronic format that allows electronic processing. Everything else, paper or a plain PDF, is a sonstige Rechnung ("other invoice").

Receiving comes first. Every business established in Germany must be able to receive e-invoices, and there are no exceptions. That includes freelancers and Kleinunternehmer. An e-mail inbox is enough, and you don't need a separate one for e-invoices. Sources: the Federal Ministry of Finance (BMF) e-invoice FAQ, questions 3, 8 and 12 (German), and the BMF letter of 15 October 2025, section 14.1 (5) UStAE.

When do you have to send e-invoices?

The transition rules are in § 27 (38) UStG. What counts is the date of your supply, not the invoice date.

Supply made in	What you may send	Condition
2025 and 2026	Paper, a PDF or an e-invoice	Paper always works. A PDF needs your customer's consent, which can be implicit. The invoice must go out by 31 December 2026.
2027	Paper, a PDF or an e-invoice	Only if your total turnover in 2026 was €800,000 or less. A PDF again needs consent. The invoice must go out by 31 December 2027.
2027	An existing EDI format	With your customer's consent, until 31 December 2027.
From 1 January 2028	E-invoice only	For every invoice to another business in Germany, unless an exception below applies.

The BMF explains the same steps in question 11 of its e-invoice FAQ and in paragraphs 62 to 65 of the BMF letter of 15 October 2024. The €800,000 means total turnover under § 19 (2) UStG (§ 27 (38) UStG). Advance and partial invoices issued before the mandate applies to you don't have to be redone as e-invoices, even if the work and the payment come later (BMF letter of 15 October 2026, para. 2).

Which invoices are exempt?

The mandate only applies where VAT law requires an invoice to another business, and where both you and your customer are established in Germany (§ 14 (2) UStG). You don't need an e-invoice for:

Private customers (B2C). They are not covered at all.
Many VAT-exempt supplies under § 4 Nr. 8 to 29 UStG, such as exempt financial services or letting of property.
Small invoices with a total of up to €250 gross (§ 33 UStDV).
Tickets for passenger transport that count as invoices (§ 34 UStDV).
Kleinunternehmer. Their invoices may always be a sonstige Rechnung (§ 34a UStDV). The scheme applies if your turnover was at most €25,000 last year and stays at most €100,000 this year (§ 19 UStG). Once you switch to standard VAT, you must send e-invoices like everyone else.
Cross-border invoices. If you or your customer is not established in Germany, there is no obligation. A client in Austria or France gets paper, or a PDF or e-invoice if the client agrees.

Sources: question 4 of the BMF FAQ and section 14.1 (6) UStAE in the BMF letter of 15 October 2025. For the VAT side of invoices to EU clients, such as reverse charge, see EU invoice VAT rules for freelancers. Which other countries have their own mandates is covered in e-invoicing mandates in Europe 2026.

What counts as an e-invoice?

An e-invoice must follow the European standard EN 16931. The BMF FAQ (question 7) names the two usual German formats: XRechnung, and ZUGFeRD from version 2.0.1, except the MINIMUM and BASIC WL profiles. Other EN 16931 formats are allowed too. Which one you use is for you and your customer to agree (BMF letter of 15 October 2025, section 14.1 (12) UStAE).

A plain PDF sent by e-mail is a sonstige Rechnung, not an e-invoice (BMF FAQ, question 2).
A broken file is not an e-invoice either. If the XML does not match the format's syntax (a "format error"), the file counts as a sonstige Rechnung (BMF letter of 15 October 2025, para. 6a).
A business rule error, such as a VAT amount that doesn't match the rate, is different. For VAT purposes the file is still an e-invoice. It only becomes a faulty invoice if a mandatory invoice detail is affected (BMF letter of 15 October 2026, paras. 22 and 23).
The XML wins. In a hybrid invoice, the structured data is what counts. If the PDF says something else, the XML applies (BMF FAQ, question 12a).
Mandatory details belong in the structured data. That includes the description of your service. A timesheet breakdown can go in an attachment embedded in the e-invoice (BMF FAQ, question 7a; BMF letter of 15 October 2026, para. 12).

XRechnung or ZUGFeRD?

Both are valid for invoices between businesses. They differ in how people read them.

	XRechnung	ZUGFeRD / Factur-X
What it is	Pure XML file	PDF/A-3 with the XML embedded
Readable without software	No, you need a viewer	Yes, it opens like any PDF
Published by	KoSIT, as the standard for invoices to German public authorities	FeRD, together with the French forum FNFE-MPE
Valid e-invoice in German B2B	Yes	Yes, from version 2.0.1, except MINIMUM and BASIC WL

Sources: BMF FAQ, questions 7 and 12a; the FeRD page on ZUGFeRD.

For freelancers a hybrid ZUGFeRD/Factur-X invoice in the EN 16931 profile is usually the simplest choice. Customers with invoice software read the XML. Everyone else opens the PDF. You don't need a Leitweg-ID for business customers. That routing ID is only for invoices to public authorities, and in B2B a placeholder such as "-" in field BT-10 is enough (BMF FAQ, question 6).

What happens if you send a PDF after the deadline?

Once an e-invoice is required, a PDF is not a proper invoice. In principle your customer cannot deduct input VAT from it (BMF letter of 15 October 2025, section 15.2a (1) UStAE). Your customer can also demand a proper e-invoice from you (section 14.1 (10) UStAE in the same letter). Sending the PDF is not an administrative offence under § 26a UStG (BMF letter of 15 October 2026, para. 28).

Checklist: what freelancers should do now

Set up receiving. Pick the e-mail address where suppliers send invoices. Make sure you can open an XRechnung, not just PDFs.
Archive the XML. Keep incoming and outgoing invoices for eight years (§ 14b UStG). For an e-invoice, at least the structured part must be kept unchanged in its original form (BMF FAQ, question 13).
Find your deadline. Check your total 2026 turnover. Above €800,000 you send e-invoices from 1 January 2027, otherwise from 1 January 2028 (§ 27 (38) UStG). As a Kleinunternehmer you have no sending obligation while you use the scheme (§ 34a UStDV).
Invoice 2026 work in 2026. The paper and PDF option for 2025 and 2026 supplies covers invoices sent by 31 December 2026 (§ 27 (38) No. 1 UStG).
Switch your own invoices early. An e-invoice to another German business needs no consent from your customer (section 14.1 (4) UStAE, BMF letter of 15 October 2025). Use ZUGFeRD/Factur-X in the EN 16931 profile or XRechnung.
Put the service description into the invoice. A reference to an attachment that holds the mandatory details is not enough (BMF FAQ, question 7a). Embed the timesheet in the e-invoice as an extra.
Validate before you send. Then keep the report.

How can a freelancer check an e-invoice?

There are two separate questions: is the file technically correct, and what does it say?

Technical check: upload the file to the free e-invoice validator. It takes a ZUGFeRD or Factur-X PDF and an XRechnung XML file, needs no account, explains the result in plain language and shows a valid invoice readably. The BMF recommends validating when you create and send an e-invoice, and suggests keeping the validation report as evidence (BMF FAQ, question 7; BMF letter of 15 October 2025, para. 35a).
Reading it: the tax administration offers a free e-invoice viewer on ELSTER for XRechnung and ZUGFeRD files (BMF FAQ, question 12a).
Content check: a passed validation doesn't mean the tax rate or the description is right. You still have to check that yourself (BMF letter of 15 October 2025, para. 35a).

If you write your invoices in yourtinyoffice, each one is created as a ZUGFeRD/Factur-X PDF/A-3 with EN 16931 XML and validated before it goes out. The deadlines above then mostly come down to receiving and archiving.

Sources

Status 29 October 2026. This guide is not legal or tax advice. The BMF will review the rules again for Germany's planned electronic reporting system, so check the sources above or ask your tax advisor before you rely on a detail.

Frequently asked questions

Do freelancers in Germany have to receive e-invoices?

Yes. Since 1 January 2025 every business established in Germany must be able to receive e-invoices, including freelancers and Kleinunternehmer. An e-mail inbox is enough.

When do I have to send e-invoices as a freelancer in Germany?

For supplies in 2025 and 2026 you may still send paper, or a PDF if your customer agrees. In 2027 that only applies if your total turnover in 2026 was €800,000 or less. From 1 January 2028 invoices to other German businesses must be e-invoices.

Do Kleinunternehmer have to send e-invoices?

No. Under § 34a UStDV their invoices may always be paper or another format, but they must still be able to receive e-invoices. Once you switch to standard VAT, the e-invoice rules apply to you too.

Is a PDF invoice sent by e-mail an e-invoice?

No. A plain PDF is a sonstige Rechnung (other invoice). XRechnung and ZUGFeRD from version 2.0.1, except the MINIMUM and BASIC WL profiles, meet the EN 16931 requirements for an e-invoice.

Do I need e-invoices for private or foreign clients?

No. The mandate covers invoices to other businesses where both you and your customer are established in Germany. Private customers and clients abroad are not covered.

How can I check an e-invoice for free?

Upload a ZUGFeRD or Factur-X PDF or an XRechnung XML file to the free yourtinyoffice e-invoice validator for a technical check. To read the content, the ELSTER e-invoice viewer is free. A passed validation does not confirm that the tax rate or description is correct.