Since January 1, 2025, the accounting landscape in Germany has permanently changed. With the implementation of the Growth Opportunities Act (Wachstumschancengesetz), receiving structured electronic invoices (E-Rechnungen compliant with EN 16931) became mandatory for domestic B2B transactions, alongside transition periods for issuing e-invoices through 2028.
Now, in 2026, the transition period for receiving invoices is over. Paper invoices and standard PDFs are rapidly being replaced by structured data formats like XRechnung and ZUGFeRD. Is your company truly 100% compliant with GoBD and the new digital workflows? Use our detailed checklist to audit your operations.
1. Status Quo: What Has Changed Since 2025?
The most critical rule that every company (including small businesses and freelancers) has been obligated to follow since January 1, 2025, relates to receiving invoices.
Mandatory Receipt: If your B2B supplier sends you an invoice in a structured electronic format (like XRechnung), you are legally required to accept it. You can no longer demand a paper copy or a standard PDF. The requirement for the recipient to explicitly consent to electronic invoices has been abolished.
2. Transition Periods: When is SENDING Mandatory?
While receiving is already mandatory, the government provided staggered deadlines for sending e-invoices, based on revenue:
- Until December 31, 2026: Companies may still send standard PDF or paper invoices (if the recipient agrees).
- From January 1, 2027: Companies with a prior-year turnover of more than 800,000 Euros MUST send structured e-invoices.
- From January 1, 2028: The transition period ends for the remaining VAT-liable companies below the €800,000 threshold, who must issue B2B invoices in EN 16931-compliant electronic formats. Exception: small businesses under the VAT exemption (§ 19 UStG) are permanently exempt from this issuing obligation under § 34a UStDV, but must still be able to receive e-invoices.
Which formats are allowed for sending? A simple PDF exported from Word or Excel is no longer sufficient. What's required is a structured, machine-readable format compliant with EN 16931. The two most common standards in Germany:
| Format | Structure | Application Area |
|---|---|---|
| XRechnung | Pure XML dataset (Code). No direct visual interface. | Mandatory for invoices to public authorities (B2G). Increasingly used in corporate B2B. |
| ZUGFeRD | Hybrid format (PDF/A-3 with embedded XML file). | Popular among SMEs, as the invoice remains human-readable while machines can extract the data. |
3. The Audit Checklist: Is Your Business Ready?
Step 1: Inbound Invoice Processing
- Do you have a dedicated email address for receiving invoices (e.g.,
[email protected])? - Can your software automatically read XML data and present it visually?
- Do you validate incoming files? (If you are unsure whether a received file complies with EU standards, you can quickly use our ZUGFeRD Validator to check for syntax errors).
Step 2: Outbound Invoice Creation
- Does your current billing software support XRechnung and ZUGFeRD exports (EN 16931 profile)?
- Do you know how to apply a Leitweg-ID for government clients?
- If you want to digitize instantly without complex IT projects, you can create an e-invoice on our platform in just a few clicks.
Step 3: Master Data Management
Structured e-invoices do not tolerate missing fields.
- Are your B2B clients' legal entities (GmbH, UG, etc.) and addresses perfectly maintained in your CRM/ERP?
- Have you collected the VAT ID (USt-IdNr.) or Tax Number (Steuernummer) for all partners?
- (Tip: To visualize exactly which fields are strictly required now, we suggest you Solobuch platform as a reference).
Step 4: GoBD-Compliant Archiving
- Do you archive electronic invoices in their original format (the XML or ZUGFeRD PDF/A-3 file itself, not a printout)?
- Does your digital archive ensure unalterability (Revisionssicherheit) for the legally required 8 years (since 1 Jan 2025, previously 10 years)?
Key Takeaways
The e-invoicing mandate is the strict reality of 2026. Every business must be capable of receiving structured invoices right now. Treat this not as a burden, but as an opportunity: automated billing speeds up payments, reduces manual entry errors, and eliminates paper costs entirely.
