Germany’s E-Rechnungspflicht is already half in force: since 1 January 2025 every business established in Germany must be able to receive structured e-invoices for domestic B2B supplies, and the duty to issue them arrives on 1 January 2027 and 1 January 2028. Germany prescribes a format (EN 16931) but no channel, so e-mail is legal and Peppol optional. Below: the dates and the law behind them, the qualifying formats, the Leitweg-ID, archiving, and what German suppliers need once Slovak customers move to Peppol in 2027. Last verified 10 October 2026.
Timeline: receive since 2025, issue from 2027 and 2028
| Date | What applies | Legal basis |
|---|---|---|
| 1 January 2025 | Every German-established business must be able to receive EN 16931 e-invoices; an e-mail inbox suffices. | § 14 UStG; BMF letter 15 Oct 2024, Rz. 40 and 62 |
| until 31 December 2026 | Paper, or with the recipient’s consent a PDF or other non-compliant format, still allowed for every issuer. | § 27 (38) no. 1 UStG |
| 1 January 2027 | Issuing becomes mandatory for domestic B2B if the issuer’s total turnover in the previous calendar year exceeded €800,000. | § 27 (38) no. 2 UStG |
| until 31 December 2027 | Issuers at or below €800,000 may still use “other invoices” with consent; EDI (Recommendation 94/820/EC) stays allowed for everyone with consent. | § 27 (38) nos. 2 and 3 UStG |
| 1 January 2028 | E-invoices mandatory for all domestic B2B supplies. | § 14 (2) sentence 2 no. 1 UStG |
The threshold is the Gesamtumsatz under § 19 (2) UStG of the previous calendar year; in a VAT group the whole group counts (BMF Rz. 64). Receiving has no transition, and a recipient who cannot or will not receive an e-invoice has no right to demand paper or a PDF instead.
Legal basis: Wachstumschancengesetz, § 14 UStG and the two BMF letters
The Wachstumschancengesetz of 27 March 2024 (BGBl. 2024 I Nr. 108) rewrote § 14 UStG: an elektronische Rechnung is an invoice in a structured electronic format compliant with EN 16931 (Directive 2014/55/EU); everything else, paper included, is a sonstige Rechnung (“other invoice”). § 14 (2) sentence 2 no. 1 requires an e-invoice for supplies between two German-established businesses unless the supply is exempt under § 4 nos. 8 to 29; the transition sits in § 27 (38).
The Federal Ministry of Finance explained the rules in its letter of 15 October 2024 (GZ III C 2 - S 7287-a/23/10001 :007, BStBl I p. 1320), amended on 15 October 2025 (GZ III C 2 - S 7287-a/00019/007/243). The 2025 letter draws a practical line: a file with format errors is not an e-invoice at all, whereas business-rule errors such as a missing BT-10 buyer reference leave it an e-invoice that may need correcting.
Exempt from the issuing duty are supplies exempt under § 4 nos. 8 to 29 UStG, small-amount invoices up to €250 (§ 33 UStDV), passenger tickets (§ 34 UStDV), invoices of Kleinunternehmer under § 19 UStG (§ 34a UStDV, since 1 January 2025) and B2C or cross-border supplies. Kleinunternehmer must still be able to receive e-invoices.
Formats: XRechnung, ZUGFeRD/Factur-X and what does not qualify
Germany prescribes a standard, not a single format: anything compliant with EN 16931 and its syntax list qualifies (BMF Rz. 25 and 26).
- XRechnung, the German CIUS of EN 16931, maintained by KoSIT in Bremen for the IT-Planungsrat; pure XML in UBL 2.1 or UN/CEFACT CII syntax. Version 3.0 has applied since 1 February 2024 and stays valid until at least 31 July 2027; a preview of XRechnung 4.0 appeared in September 2026, with the final version expected in spring 2027.
- ZUGFeRD (identical to the French Factur-X): a PDF/A-3 with embedded CII XML. It qualifies from version 2.0.1, except the profiles MINIMUM and BASIC-WL; the XML is the leading part and prevails over the PDF image (Rz. 31).
- Other EN 16931 formats, explicitly including Peppol BIS Billing, are equally permitted; the choice is a civil-law matter between the parties (Rz. 27).
What does not qualify: PDF, scans, paper and invoice data typed into an e-mail (all “other invoices”, allowed only within the transition or where exempt), ZUGFeRD before 2.0.1 and the MINIMUM and BASIC-WL profiles. EDIFACT and other EDI formats pass with consent until 31 December 2027 and afterwards only if the data can be extracted completely into an EN 16931 format (§ 14 (1) sentence 6 no. 2 UStG). Syntax details for UBL, CII, BIS 3.0 and PINT: Peppol document formats.
Transmission: e-mail is legal, Peppol is one channel
The law regulates the document, not the pipe. The BMF accepts e-mail, electronic interfaces, shared storage within a group and portal downloads (Rz. 36), confirms that an ordinary e-mail inbox satisfies the receiving duty (Rz. 40) and allows external service providers, with the issuer remaining responsible (Rz. 37). Peppol is therefore not mandatory for German B2B invoicing. The German Peppol Authority is KoSIT; companies join through a service provider (an Access Point) or their own OpenPeppol membership. Peppol still wins in four situations:
- Public-sector buyers: federal bodies accept Peppol as a mass-volume channel, as do many Länder and municipalities.
- Buyers abroad whose mandate runs on Peppol: Slovakia’s 2027 mandate works through certified delivery services on the Peppol network, and Belgium’s B2B mandate (in force since 1 January 2026) is built around Peppol too. One connection reaches all of them; see the country overview.
- Proof and validation: an Access Point validates the XML against EN 16931 and the BIS rules before sending and returns MLS delivery receipts; e-mail offers neither.
- Future reporting: the BMF expects e-invoicing platforms to matter for Germany’s planned transaction-based reporting system (Rz. 41), and ViDA makes digital reporting mandatory for intra-EU B2B from 1 July 2030.
B2G: Leitweg-ID, OZG-RE and KoSIT
Suppliers to the federal administration have had to submit e-invoices since 27 November 2020 (§ 3 (1) E-RechV), except for direct orders up to €1,000 (§ 3 (3) no. 1 E-RechV). The standard is XRechnung in its current version. Since September 2025 the whole federal administration receives e-invoices through one central platform, the OZG-RE, into which the former ZRE was merged; suppliers register once, free of charge, and submit by web form, upload, e-mail or Peppol.
The Leitweg-ID is the routing identifier of a public buyer. KoSIT’s specification (version 2.0.2, 28 July 2021) defines three hyphen-separated parts: a Grobadressierung of 2 to 12 digits (federal bodies use 991, 992 or 993), an optional Feinadressierung of up to 30 alphanumeric characters and a two-digit check digit per ISO/IEC 7064 MOD 97-10; the specification’s example is 04011000-1234512345-06. It belongs in the buyer reference (BT-10), and the OZG-RE rejects invoices without it. On Peppol it doubles as the address: the Leitweg-ID is registered under ISO/IEC 6523 as ICD 0204, so a federal body’s participant ID is 0204: plus its Leitweg-ID, as the federal e-invoicing portal describes.
Archiving: GoBD and the eight-year retention period
The Viertes Bürokratieentlastungsgesetz (BGBl. 2024 I Nr. 323) cut the retention period for invoices and accounting vouchers from ten to eight years in § 14b (1) UStG and § 147 (3) AO, effective 1 January 2025 for documents whose period had not yet expired (§ 27 (40) UStG). At least the structured part of an e-invoice must be kept unaltered in its original, machine-readable form (Rz. 60). The GoBD principles (BMF letter of 28 November 2019, last amended 14 July 2025) govern electronic bookkeeping; the 2025 letter adds that storing e-invoices outside a GoBD-compliant system is not in itself a breach of § 14b UStG.
For clarity: the Verteco Data archive keeps original XML in the EU (1 GB per company) for as long as you use the service. It is not a statutory archive, and long-term retention remains the taxpayer’s duty.
German suppliers invoicing Slovakia from 2027
Slovakia’s act no. 385/2025 Coll. (amending VAT act 222/2004) starts on the same day as Germany’s first issuing step. From 1 January 2027 Slovak VAT payers must issue structured e-invoices for domestic supplies (§ 85o) and practically every Slovak business must be able to receive them through a certified delivery service on the Peppol network (§ 71 (5)); e-mail PDF or EDI remain legal only with the recipient’s consent, and only until 30 June 2030. Cross-border supplies are expected to follow with ViDA from 1 July 2030, according to the Slovak Financial Administration; see the Slovak mandate 2027.
A Slovak subsidiary (s.r.o.) of a German group that is registered for VAT, as most are, falls fully under the mandate including the duty to issue; a non-VAT-payer subsidiary must at least be able to receive. A German company without a Slovak establishment is not covered by the 2027 issuing duty, but its Slovak customers will be on Peppol and can lawfully stop accepting PDFs. What a German supplier needs:
- The buyer’s Peppol ID: scheme 0245 plus the ten digits of the Slovak tax number (DIČ), no “SK” prefix, e.g.
0245:2021234567;9950:SK…exists only on the test network. - A UBL 2.1 invoice per Peppol BIS Billing 3.0: XRechnung UBL carries German-specific rules, so generate or map to plain BIS Billing 3.0.
- Any Peppol Access Point: German providers deliver to Slovak participants without extra agreements or roaming fees.
- Nothing extra for Slovak tax reporting: the Slovak mandate and its Tax Data Document (TDD, the “C5 report”) cover domestic invoices issued by Slovak VAT payers, so a cross-border invoice from a German supplier carries no Slovak reporting duty in 2027; cross-border reporting is expected only with ViDA from 1 July 2030.
The German Peppol ID: 9930 plus VAT ID, lookup and registration
In the Peppol EAS code list, scheme 9930 is “Germany VAT number”, so a German company’s participant ID is 9930:DE followed by the nine digits of its USt-IdNr., for example 9930:DE123456789; public bodies use 0204:<Leitweg-ID>. To check reachability, the Peppol Directory lists participants who publish a business card, and an SML/SMP lookup is the authoritative check for any scheme. Our free Peppol ID checker does exactly that. A company not yet on the network is registered by its service provider in that provider’s SMP; only one provider can hold the receiving capability for a participant and document type at a time. More in Peppol ID and registration.
Where Verteco fits, and where it does not
Verteco digital services, s. r. o. (Žilina) operates its own certified Peppol Access Point, accredited by the Slovak Financial Administration (decision no. 605502941/2026 of 26 May 2026, PA SK ID EFSK000031 (seat PSK001128)), and has been an OpenPeppol member since 24 April 2026 with 19/19 conformance tests passed and a production PKI certificate. We are a Slovak-accredited provider, not a German tax or XRechnung specialist.
Our Access Point sends and receives UBL 2.1 invoices and credit notes per Peppol BIS Billing 3.0 to and from any Peppol participant, German 9930 addresses included, with validation, MLS delivery receipts, a REST API and webhooks. German public bodies (0204) generally require XRechnung, which we do not produce, so delivery to them depends on the recipient having registered the BIS Billing 3.0 document type or on a mapping agreed in advance. The same applies to ZUGFeRD; a mapping from XRechnung or CII to UBL is available on request, priced by scope. Data is processed in the EU (Frankfurt, encrypted standby copy in Bratislava), the sandbox, UBL validator and Peppol ID check are free, and ISO/IEC 27001 certification is in progress and being handled in line with Peppol requirements. As of 10 October 2026, 66+ companies and public bodies are connected through our service. Receiving without the Data archive is free (fair use up to 1,000 invoices a month); the complete service costs €2 + VAT per company per month from 1 January 2027.
Next step
If you run a Slovak s.r.o., or your German company receives Peppol invoices from Slovak partners, register your company and test the flow in the sandbox before 1 January 2027. Developers mapping a German system to BIS Billing 3.0 will find the API reference and UBL samples in the portal documentation. The full topic cluster starts at our Peppol hub.
