Germany’s Federal Ministry of Finance updated its FAQ on the mandatory electronic invoicing rules, with the latest version dated March 2026.
The FAQ explains the new rules introduced by the Growth Opportunities Act, under which electronic invoices generally became required for transactions between domestic businesses from January 1, 2025. Transitional rules apply, and private consumers are not affected.
The Ministry clarifies that, since 2025, an electronic invoice must be issued, transmitted, and received in a structured electronic format that allows electronic processing. A simple PDF no longer qualifies as an e-invoice and is treated as an “other invoice.”
The FAQ confirms that German businesses must be able to receive e-invoices from January 1, 2025, with an email inbox generally sufficient for receipt. However, businesses may continue issuing paper invoices or other non-structured invoices during the transitional period through 2026. Businesses with prior-year turnover of up to €800,000 may use the extended transition period through 2027.
The FAQ also addresses permitted formats, including XRechnung and ZUGFeRD from version 2.0.1, required structured invoice data, treatment of corrected invoices and construction invoices, retention obligations, and submission of e-invoices to the tax authorities through ELSTER.
The update further notes that the e-invoicing framework is intended to support a future transaction-based VAT reporting system.
