#Germany's B2B E-Invoicing Mandate

Germany's B2B e-invoicing mandate, introduced by the Wachstumschancengesetz, phases in structured EN 16931 e-invoices for domestic business-to-business transactions: all businesses must be able to receive them from 1 January 2025, and the obligation to issue them applies from 2027 for larger firms and from 2028 for nearly all businesses. A plain PDF does not count — the mandate is about structured, machine-readable invoices.

This page describes the mandate factually and in general terms. It is not tax or legal advice. Your specific obligations depend on your circumstances — confirm them with a qualified tax advisor.

#What the mandate is

The Wachstumschancengesetz (Growth Opportunities Act) amended §14 of the German VAT Act (UStG) to require structured electronic invoices for domestic B2B transactions, replacing paper and unstructured PDFs over a multi-year transition. The goal is the same as the EU directive behind EN 16931: invoices that systems can process automatically.

#Timeline at a glance

A transitional period allows certain non-structured invoices during the phase-in, subject to conditions such as recipient agreement. Because the exact transitional rules and dates are detailed and have been clarified over time, this page states the firm milestones and points you to the official source rather than asserting a single cut-off.

#"Receive capability" vs "issue obligation"

These are two different things, which is why the dates differ:

• Receive capability (from 2025): a business must be technically able to accept and process an incoming structured e-invoice. In practice this can be as simple as being able to receive the file and read it.
• Issue obligation (2027 / 2028): a business must actually send its domestic B2B invoices as structured e-invoices, not paper or plain PDF.

#Which formats satisfy the mandate?

Any EN 16931-conformant structured format, including:

• XRechnung — pure XML, also the B2G standard.
• ZUGFeRD at BASIC profile or above — the hybrid PDF most common for B2B. (MINIMUM and BASIC-WL do not qualify.)
• Peppol BIS — for invoices exchanged over the Peppol network.

A plain PDF is unstructured and does not meet the requirement on its own — see e-invoice vs PDF for why.

#How Scribo helps you comply with the format requirement

Meeting the mandate means producing a valid structured invoice, and that's the part that's easy to get wrong. Scribo generates EN 16931-conformant XRechnung and ZUGFeRD files from a plain description of the invoice, validating each one at generate time, for free and with no signup form. It produces the structured file the mandate calls for — you can run it from the web app, the HTTP API, the hosted MCP server, the CLI, or the Claude/Codex skill, so even an automated billing workflow ends with a compliant document. (Scribo produces the invoice file; it does not advise on whether or when the mandate applies to you — that's a question for your tax advisor.)

#Frequently asked questions

When does the German e-invoicing mandate start? The phase-in began on 1 January 2025, when all domestic German businesses became required to be able to receive structured EN 16931 e-invoices. Obligations to issue them follow in 2027 and 2028. Exact obligations depend on the business; confirm yours with a qualified advisor.

What formats satisfy the German B2B mandate? An EN 16931-conformant structured e-invoice — for example XRechnung, a ZUGFeRD profile at BASIC or above, or Peppol BIS. A plain PDF is not a structured e-invoice and does not satisfy the requirement.

Is a PDF invoice still allowed under the mandate? An ordinary emailed PDF is treated as an unstructured invoice. During the transition there is tolerance for non-structured invoices under certain conditions, but the direction of the mandate is toward structured EN 16931 formats. The specifics depend on the year and the parties, so confirm your situation with an advisor.

Does the mandate apply to B2C or cross-border invoices? The mandate concerns domestic German business-to-business (B2B) transactions. Business-to-consumer (B2C) and cross-border invoices are outside its core scope. This page describes the rules generally and is not advice on a specific case.

What is the legal basis for the mandate? It was introduced by the Wachstumschancengesetz (Growth Opportunities Act), which amended §14 of the German VAT Act (UStG) to require structured electronic invoices for domestic B2B transactions, phased in over several years.

Sources: §14 UStG (gesetze-im-internet.de); Bundesministerium der Finanzen — E-Rechnung; EU Directive 2014/55/EU.