EU · BMF (Bundesministerium der Finanzen) / Bundeszentralamt für Steuern
Germany
Updated in last 30 days·Atlas data current as of
Wachstumschancengesetz introduces mandatory B2B e-invoicing in phases. Receive obligation already live since 1 Jan 2025. Issue obligation Jan 2027 for >€800k turnover; all B2B from Jan 2028. No central reporting platform.
Cloudare has shipped 2 🇩🇪 Germany integrations · talk to us →// Phased rollout
- 01 Jan 2025 · liveReceive obligationAll domestic B2B taxable persons must be able to receive structured e-invoices.
- 01 Jan 2025 → 31 Dec 2026 · liveTransition allowancePaper and PDF still permitted with recipient consent.
- 01 Jan 2027 · upcomingIssue obligation — largeIssuers above threshold must send EN 16931-compliant invoices.Prior-year turnover > €800,000
- 01 Jan 2028 · upcomingIssue obligation — all B2BAll B2B issuers must send structured e-invoices.
// Penalties
AO §379: up to €5,000 fine per non-compliant invoice; ITC denial for recipient if invoice not in valid format after mandate.
// What you have to do
- Confirm which of your flows are in scopeB2B is phased, B2G is mandatory.
- Emit one of XRechnung 4.0 or ZUGFeRD ≥ 2.1 (Factur-X compatible) or EN 16931 compliant XMLYour ERP must produce this syntax, not a PDF or a print stream.
- Connect via Direct exchange (no central platform initially) or Peppol (B2G via Bund/Länder)This is the channel, separate from the format. Most projects underestimate it.
- Plan for the Post-Audit modelReporting happens after issuance, so correctness is your responsibility rather than the regulator's gate.
- Retain for 10 yearsArchive the structured original, not a rendering of it.
- Understand the exposureAO §379: up to €5,000 fine per non-compliant invoice; ITC denial for recipient if invoice not in valid format after mandate.
// ERP implementation notes
SAP S/4HANA (incl. DRC) & SAP ECC
SAP DRC Germany: ZUGFeRD/XRechnung output via eDocument DE_INVOICE. PDF/A-3 with embedded XML supported. Receipt processing via SAP Business Network or DCC.
Microsoft Dynamics 365 (F&O + Business Central)
D365 BC and F&O support XRechnung 3.0/4.0 via E-Document app and ER. Peppol partner connector for B2G.
Oracle Fusion Cloud ERP
Oracle Fusion DE localisation + Edicom/Sovos for outbound; PDF/A-3 generation via BIP.
Oracle NetSuite
EU EI SuiteApp ships XRechnung CIUS template; ZUGFeRD via partner PDF/A-3 plugin.
Odoo (Community + Enterprise)
l10n_de_xrechnung + account_edi_ubl_cii produces both XRechnung and ZUGFeRD 2.1/2.3.
Zoho Books / Zoho One
Zoho Books DE supports ZUGFeRD/XRechnung; receive via email parser + Peppol AP.
// Implementation playbook
Cloudare has shipped 2 Germany integrations. We will email you the full implementation playbook for Germany — typical project plan, ERP-by-ERP gotchas, regulator-specific edge cases, sample test data. No marketing.
// Frequently asked questions
When does Germany's B2B mandate apply to us?
Phased rollout: from 1 January 2025 all German VAT-registered businesses must be able to receive structured e-invoices (this is live). From 1 January 2027 businesses with prior-year turnover > €800,000 must issue. From 1 January 2028, all remaining businesses (SMEs) must issue. B2G has been live since 2020 via XRechnung.
XRechnung or ZUGFeRD — which one do we issue?
Both are accepted. XRechnung is the pure structured XML CIUS of EN 16931, mandatory for B2G submissions to Bund (federal) entities. ZUGFeRD 2.3 / Factur-X 1.07 is the hybrid PDF/A-3 + embedded CII XML — more common in B2B. Many businesses output ZUGFeRD by default and XRechnung when sending to government.
Do we have to use Peppol?
Not mandatory for B2B — Germany's mandate is format-based, not transmission-based. You can send via Peppol, email, EDI, portal, or any agreed channel as long as the format is structured (XRechnung or ZUGFeRD). For B2G to federal entities, the ZRE/OZG-RE portal accepts XRechnung.
What about PDF invoices — are they done?
From 1 January 2027 (for >€800K businesses) and 1 January 2028 (for all), pure PDF or paper invoices are no longer compliant for domestic B2B. A PDF wrapped in ZUGFeRD (i.e., with the embedded CII XML) is still compliant — that's the migration path most German SMEs will take.
Which ERPs are ready for Germany?
SAP DRC and SAP Document Compliance for Germany. Oracle Fusion via Tax Reporting Cloud + German localisation. Microsoft Dynamics 365 F&O with the German localisation pack. DATEV and Sage are dominant in German mid-market and have native XRechnung/ZUGFeRD support. Odoo and Zoho have functioning German modules.
Are there penalties before 2027 if I'm not ready to receive?
Yes — failure to be able to receive structured e-invoices from 1 January 2025 is itself a compliance failure, even if your suppliers haven't started sending yet. The penalty schedule sits within the existing UStG (German VAT law) framework, with administrative fines per violation.