Since 1 January 2025, every VAT-registered business in Germany has been legally required to receive structured electronic invoices — in XRechnung or ZUGFeRD format. Twenty-two months later, the picture is mixed: reception works well for early adopters and large enterprises, but a significant share of SMEs and mid-market companies remains in a grey zone, according to a representative survey of 1,103 companies with more than 20 employees published by Bitkom in December 2024. And the next milestone is just 11 weeks away: on 1 January 2027, companies exceeding €800,000 in annual turnover will also be required to send structured e-invoices.
Germany’s Three-Step E-Invoicing Timeline
Germany opted for a sequenced approach, unlike several other European countries that imposed reception and sending obligations simultaneously:
- 1 January 2025: reception mandate for all VAT-registered businesses — every company must be able to receive and process a structured electronic invoice compliant with EN 16931
- 1 January 2027: sending mandate for companies whose prior-year turnover exceeds €800,000
- 1 January 2028: sending mandate extended to all businesses, including SMEs below the €800,000 threshold
These obligations apply exclusively to B2B transactions between VAT-registered businesses established in Germany. Intra-EU supplies, B2C sales, and Kleinunternehmer (micro-enterprises under Article 19 UStG) are out of scope.
Accepted Formats
Two national formats compliant with the European standard EN 16931 are valid:
XRechnung: pure XML format, native to public-sector invoicing (B2G) since 2020 and now also widely used in B2B. Ideal for fully automated workflows, but requires an ERP or dedicated reading tool on the receiving side.
ZUGFeRD: a hybrid format combining a PDF layer with an embedded XML file, far more accessible for accounting teams who need human-readable documents. Version 2.5, released on 20 May 2026 by the Forum Elektronische Rechnung Deutschland (FeRD), introduced support for gross invoices in the book, publishing, and petroleum sectors, and aligned the format with the latest EN 16931 code lists (source: ZUGFeRD 2.5, VATupdate).
PDF-only invoices, Word files, and Excel spreadsheets have no longer been compliant with reception requirements since 1 January 2025.
Unlike France, Germany has not established a centralized national platform. Transmission is decentralized, peer-to-peer, directly between company systems or via e-invoicing service providers.
What Has Worked Well
Large Enterprises and Mid-Market Companies Were Already Ahead
Companies that had already implemented electronic invoicing for the public sector (B2G) since 2020 entered with a meaningful head start. Major ERP platforms — SAP, Microsoft Dynamics 365, Odoo, Sage X3 — all delivered compliant modules before 1 January 2025. Multi-entity groups with international operations, accustomed to managing multiple formats and tax frameworks, had integrated XRechnung or ZUGFeRD into their invoicing workflows well before the regulatory deadline.
For these early movers, the switch was operational: reception flows are live, accounting teams have been trained, and interoperability tests with key trading partners were completed in advance.
ZUGFeRD Has Become the De Facto Format for SMEs
Format preference was confirmed by Bitkom data: 27% of surveyed companies use ZUGFeRD or Factur-X for reception, compared with only 5% for XRechnung (Bitkom, December 2024 survey). This gap reflects the learning curve: ZUGFeRD preserves a human-readable PDF rendering, making deployment more gradual for teams unfamiliar with pure XML workflows.
The ZUGFeRD 2.5 update in May 2026 also reassured ERP teams about the format’s longevity, demonstrating active governance and a clear path toward future European standards.
The Service Provider Ecosystem Has Taken Shape
In the absence of a national platform, a market of e-invoicing service providers has emerged: Peppol-certified operators, XRechnung/ZUGFeRD connector vendors, specialized integrators. Companies without a native ERP module can route through these intermediary layers to achieve compliance.
What Is Still Blocking
A Reception Rate That Remains Too Low
The numbers are stark: only 45% of German businesses were effectively capable of receiving e-invoices by end-2024 — essentially at the moment the mandate came into force (Bitkom, December 2024). At the same time, 96% of companies continued receiving invoices by email, and 93% still accepted paper invoices from their suppliers.
This reflects the gap between the legal obligation and operational reality: many businesses have not been penalized for non-compliance on the reception side, which reduced the pressure for immediate adaptation.
Most SMEs Have Not Updated Their Sending Processes
The 2025 obligation applied solely to reception — a passive requirement. An SME could therefore remain legally compliant by having an email address or a minimal tool capable of reading ZUGFeRD, without modernizing its own sending processes. In practice, many SMEs receive correctly but still send PDFs. This creates asymmetric pressure across the supply chain: large enterprise customers that started sending in XRechnung or ZUGFeRD do so, but their SME suppliers continue emitting PDFs without triggering any legal rejection from the sender’s side before 2027–2028.
Preparation for the 2027 Sending Mandate Remains Insufficient
The YouGov study commissioned by easybill is alarming: only one in four businesses is ready for the January 2027 sending mandate (easybill / YouGov, 2026). Cross-referencing with Bitkom data yields a precise maturity profile: 24% have completed the transition, 38% are in progress, and 29% have not yet started or are at the very beginning of planning.
The main obstacles identified (Bitkom):
- 36% of unprepared companies cite the complexity of technical implementation
- 29% are still uncertain about the exact legal requirements
- 27% lack knowledge on the topic
These figures are troubling: a company starting its e-invoicing project in October 2026 for a 1 January 2027 deadline has only 11 weeks — which is insufficient for most ERP integration scenarios.
Unstandardized Edge Cases
Certain business scenarios remain a source of friction in XRechnung implementations: intra-group transactions, advance payments, credit notes linked to prior invoices, debit notes. These cases are not always natively covered by ERP e-invoicing modules and require specific development work or documented workarounds.
Foreign suppliers not established in Germany are not subject to the sending mandate — only to reception capability. This asymmetry can create confusion in cross-border flows between European subsidiaries.
Legacy ERPs: The Underlying Problem
For companies running older on-premise ERP systems — SAP ECC pre-2020, unpatched Microsoft Navision, outdated Sage releases — compliance requires either a major version upgrade or an intermediary connector between the ERP and the e-invoicing workflow. This cost, not anticipated in original budgets, is a real barrier for SMEs on reduced maintenance contracts.
The 2027 Countdown: What CIOs Must Do Now
For Companies Exceeding €800,000 in Annual Turnover
With 11 weeks before the deadline, companies that have not yet started are in an emergency situation. The reality is straightforward: an e-invoicing integration project in an existing ERP takes three to six months depending on workflow complexity. Companies above the €800,000 threshold can no longer realistically aim for compliance “before 1 January 2027” if nothing has been started — they should target a documented good-faith posture and simultaneously launch the project for Q1 or Q2 2027 compliance.
Four priority actions to start immediately:
- Sending capability audit: does the current ERP natively support XRechnung or ZUGFeRD issuance? If not, what is the vendor’s delivery date for a compliant module?
- German B2B flow mapping: which customers will receive invoices from 1 January 2027? What is the monthly volume? Are those customers ready to receive structured formats?
- Pilot tests with two or three willing customers: a live-production pilot on a real flow before rollout — the correction cost is ten times lower than a hard cutover
- Customer master data audit: do customer records contain the correct German identifiers (Handelsregisternummer)? For public-sector flows, the Leitweg-ID is mandatory in XRechnung
For Companies Below the €800,000 Threshold
The sending mandate is deferred to 1 January 2028, but the reception obligation has been in force since January 2025. Use 2027 to modernize without pressure: select compliant invoicing software, test inbound formats, train accounting teams on reading ZUGFeRD XML. The window for unhurried preparation closes in summer 2027, when compliance projects for January 2028 will create tension on integrator resources.
Comparison with France: Two Models, Cross-Cutting Lessons
France and Germany adopted structurally different approaches on the reception/sending sequence and on national infrastructure.
| Comparison point | Germany | France |
|---|---|---|
| Reception mandate | January 2025 (all businesses) | September 2026 (all businesses) |
| Sending mandate – large enterprises | January 2027 (>€800k turnover) | September 2026 (large enterprises and mid-market) |
| National platform | None — decentralized P2P | PPF (Portail Public de Facturation) |
| Accepted formats | XRechnung, ZUGFeRD (EN 16931) | Factur-X, UBL, CII |
| Exemptions | Kleinunternehmer (micro-enterprises) | Micro-enterprises (until 2027) |
Germany’s approach — reception first, sending later — has a pragmatic advantage: companies could adapt their reception capability without immediately touching their own sending processes. This reduces initial friction and enables gradual adoption. The downside is visible today: that delay also allowed a majority of SMEs to defer modernizing their sending infrastructure, and the accumulated backlog is now coming due in the rush toward January 2027.
France opted for simultaneous reception and sending obligations for large enterprises, paired with a centralized national platform that simplifies routing but creates a single point of dependency. Early field feedback from late September 2026 shows that large French companies that prepared 12 to 18 months in advance absorbed the transition without major incidents, while SMEs on legacy ERPs experienced the same friction as in Germany — see our review of France’s first month of mandatory e-invoicing.
The cross-cutting lesson is clear: regardless of the national approach, companies that start early — 12 to 18 months before the effective deadline — navigate the transition without incidents. Those that wait for the real constraint face project delays, saturated integrator capacity, and genuine operational risk on cash collection.
Conclusion
Germany is on track but not yet at the finish line. The 18-month review of the reception mandate shows that pioneers and large enterprises have validated their flows, but fewer than half of the B2B landscape is effectively compliant. The January 2027 sending mandate for companies above €800,000 in turnover is approaching in a context of insufficient preparation for a large fraction of affected businesses: only one in four had completed the transition at the time of the latest available survey.
For CIOs and CFOs at companies within scope for the January 2027 deadline: the compliance window is already narrow. An immediate ERP audit, followed by a decision on the integration model (native module, third-party connector, or multi-ERP platform), is the irreducible first step to take in October–November 2026.
For deeper context: our complete guide to XRechnung and ZUGFeRD ERP compliance in Germany covers the technical options available by ERP type, and our ERP action plan for German B2B e-invoicing 2027 offers a six-step roadmap from scoping to deployment.
