What you need to know (TL;DR)
- The German einvoicing mandate 2025 took effect on 1 January 2025: large German enterprises (turnover >€800,000 or >249 employees) must be able to receive and process structured electronic invoices.
- Small and medium-sized businesses follow in phases: SMEs must send einvoices from 1 January 2027. Micro-enterprises (turnover <€800,000) from 1 January 2028.
- XRechnung (pure XML, CII-based, EN 16931) and ZUGFeRD 2.0 (hybrid PDF + XML) are the two dominant formats. Peppol UBL is also valid.
- The German einvoicing mandate 2025 is a full B2B obligation — not limited to government invoicing.
- Dutch and Belgian suppliers without a German establishment are formally not required — but large German customers increasingly expect einvoice-compatible suppliers.
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The German einvoicing mandate 2025 entered into force on 1 January — and marks a historic shift in how German business invoicing works. For the first time, it is not only the government requiring einvoices: large German enterprises across every sector must now accept and process structured digital invoices from their suppliers.
For Dutch and Belgian exporters supplying the German market, this changes more than it might initially appear. This article explains what the German einvoicing mandate 2025 entails, which formats apply, how the rollout timeline works, and what you need to arrange as an exporting company.
Background: how the German einvoicing mandate 2025 came about
Germany lagged behind the rest of Europe on B2B einvoicing for years. XRechnung existed as a standard for B2G invoicing (to government), but there was no legal obligation for private B2B transactions. That changed with the amendment to the Umsatzsteuergesetz (UStG) in 2024, which embedded the German einvoicing mandate 2025 in the Wachstumschancengesetz (Growth Opportunities Act).
The law does not require businesses to use XRechnung specifically — it requires them to be able to receive and process a ‘strukturierte elektronische Rechnung’ (structured electronic invoice compliant with EN 16931). XRechnung and ZUGFeRD 2.0 are the two formats that satisfy this requirement in practice.
Timeline: who must comply with the German einvoicing mandate 2025 and when?
| Date | Obligation | Target group |
|---|---|---|
| 1 January 2025 | Receipt of einvoice mandatory | All VAT-liable businesses in Germany (turnover >€800,000 or >249 employees) |
| 1 January 2027 | Sending of einvoice mandatory | SMEs in Germany (turnover between €800,000 and large enterprise threshold) |
| 1 January 2028 | Sending of einvoice mandatory | Micro-enterprises in Germany (turnover <€800,000) and remaining taxable persons |
The practical consequence for exporters: your large German customers have already reconfigured their procurement processes for automated einvoice handling. A PDF arriving by email now requires manual processing in a system that is actively being decommissioned for that purpose.
XRechnung vs ZUGFeRD 2.0: what is the difference?
Two formats dominate the German einvoicing mandate 2025 landscape:
XRechnung is a pure XML format based on UN/CEFACT CII, fully compliant with EN 16931. It is the official format for B2G invoicing in Germany and equally valid for B2B. XRechnung contains no human-readable PDF layer — it is exclusively machine-readable.
ZUGFeRD 2.0 is a hybrid format: a human-readable PDF with an embedded CII-compliant XML file. It is identical to Factur-X (also used in France) and complies with EN 16931. ZUGFeRD 2.0 is the most accessible entry point for international suppliers: it looks like a normal invoice PDF but contains the structured XML that enables automated processing.
Peppol UBL is also a valid format under the German einvoicing mandate 2025. If your Peppol service provider operates a German Peppol access point, you can send UBL invoices via Peppol to German customers — provided those customers are also Peppol-connected. This is not universal among large German businesses; always verify with the specific customer.
Comparison: Germany, Belgium and the Netherlands
| Feature | Germany (mandate 2025) | Belgium (Jan 2026) | Netherlands (ViDA 2030) |
|---|---|---|---|
| Primary format | XRechnung (CII) / ZUGFeRD 2.0 | Peppol UBL | Peppol UBL / CII |
| Transmission network | Open (email, portal, Peppol) | Peppol (mandatory) | Peppol (designated) |
| B2B receipt | Mandatory from Jan 2025 (large enterprises) | Mandatory from Jan 2026 | Not yet mandatory |
| B2B sending | Mandatory from Jan 2027 (SMEs) | Mandatory from Jan 2026 | Mandatory by Jul 2030 |
| Foreign supplier obliged? | No; practically expected | No; practically expected | N/A (B2B voluntary) |
What the German einvoicing mandate 2025 means for Dutch and Belgian exporters
Companies without a permanent establishment in Germany are formally not required to use XRechnung or ZUGFeRD. The commercial reality is developing differently — and quickly.
In the manufacturing sector (Mittelstand) and the automotive and logistics supply chains, pressure on foreign suppliers is strongest. Suppliers to large German groups such as BASF, Siemens, or BMW have long been asked to connect to the buyer’s EDI or einvoicing infrastructure — well before any formal legal obligation applied.
The practical step for exporters: check whether your Peppol service provider can generate ZUGFeRD 2.0 or XRechnung, and whether you can send invoices via Peppol to a German access point.
Practical checklist: what to arrange now for the German einvoicing mandate 2025
- Identify your large German customers: who has turnover above €800,000 or more than 249 employees? Those parties have been obliged to receive einvoices since 1 January 2025.
- Ask your customer which format they expect: XRechnung, ZUGFeRD 2.0, or Peppol UBL? Not all large enterprises accept all three.
- Check your Peppol service provider: can it generate XRechnung or ZUGFeRD? Does it have a German Peppol access point?
- Check your ERP: can it export CII or ZUGFeRD files? If not, is a plugin or connector available?
- Test before sending: send a test invoice and have your customer confirm that the XML layer has been processed correctly by their system.
Compare Peppol service providers on Peppol.now — filter on Germany support and XRechnung/ZUGFeRD compatibility.
Frequently asked questions about the German einvoicing mandate 2025
Does the German einvoicing mandate 2025 apply to me as a Dutch supplier without a German establishment?
Formally no. The legal obligation applies to VAT-liable businesses established in Germany. However, large German customers increasingly expect einvoice compatibility from all suppliers, regardless of country of establishment. The commercial pressure is significant in manufacturing and automotive supply chains.
What is the difference between XRechnung and ZUGFeRD 2.0?
XRechnung is pure XML (CII), exclusively machine-readable. ZUGFeRD 2.0 is a hybrid PDF with embedded XML — readable by humans and processable by systems. Both satisfy EN 16931 and are valid under the German einvoicing mandate 2025. ZUGFeRD 2.0 is typically the most accessible starting point for international suppliers.
Can I send XRechnung-compliant invoices via Peppol?
Yes. Peppol UBL is a valid format under the German einvoicing mandate 2025. If your Peppol service provider has a German access point and your customer is also Peppol-connected, this works. Always verify: not all large German companies have activated Peppol.
When do small businesses in Germany need to send einvoices?
SMEs (turnover between €800,000 and the large enterprise threshold) must send einvoices from 1 January 2027. Micro-enterprises (turnover below €800,000) have until 1 January 2028.
Is ZUGFeRD the same as Factur-X?
Yes. ZUGFeRD 2.0 and Factur-X are technically identical formats — both are hybrid PDF/CII-XML documents compliant with EN 16931. ZUGFeRD is the name used in Germany; Factur-X is the name used in France. A ZUGFeRD 2.0 invoice is therefore also valid in the French Plateformes Agréées system.
- German Federal Ministry of Finance — Obligation for electronic invoicing
- KoSIT — XRechnung standard and documentation
- FeRD — ZUGFeRD 2.0 format and specifications
- OpenPeppol — UBL standard and access point network
- European Commission — ViDA: VAT in the Digital Age
Compare Peppol service providers with XRechnung and ZUGFeRD support on Peppol.now. Also read our article on Netherlands ViDA einvoicing for the broader EU mandate context.
