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Invoices & accounting

Germany's E-Invoicing Mandate 2025–2028: What Still Arrives as a PDF or a Photo

German businesses must receive e-invoices since 2025; issuing becomes mandatory in 2027 above €800,000 turnover and for all in 2028. Small invoices, tickets, foreign suppliers and delivery notes stay outside it.

Updated 6 min read

Since 1 January 2025, every business established in Germany must be able to receive e-invoices for domestic B2B transactions — structured formats such as XRechnung or ZUGFeRD, not a PDF. The obligation to issue them is phased: until 31 December 2026 any business may still send paper or PDF invoices; in 2027 that remains allowed only for businesses whose prior-year turnover was €800,000 or less; from 1 January 2028 it applies to all.

So German companies are in the transition right now, and the question for whoever does the bookkeeping is practical: how much of the inbound pile will still arrive as a PDF or a phone photo, and for how long? This guide sets out the rules, the exceptions that are permanent, and how to size the manual work that is left.

The timeline

PeriodReceiving e-invoicesIssuing domestic B2B invoices
Since 1 January 2025Mandatory for all businessesPaper and PDF still allowed
2026MandatoryPaper and PDF still allowed for all
2027MandatoryE-invoice mandatory above €800,000 prior-year turnover; paper and PDF still allowed at or below it
From 1 January 2028MandatoryE-invoice mandatory for all, except the permanent exceptions

A PDF is an "other invoice" (sonstige Rechnung) under German VAT law, not an e-invoice. Hybrid ZUGFeRD files count as e-invoices because they carry the structured XML part. Confirm your own position with your tax adviser (Steuerberater) — this article is not tax advice.

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Exceptions that do not expire

Some documents stay outside the obligation even after 2028, according to the Federal Ministry of Finance guidance:

  • Small-amount invoices up to €250 (Kleinbetragsrechnungen).
  • Travel tickets (Fahrausweise).
  • Invoices from small businesses under the Kleinunternehmer scheme, which do not have to issue e-invoices.
  • B2C sales — invoices to consumers are not covered.
  • Cross-border invoices and invoices from suppliers not established in Germany.
  • VAT-exempt supplies covered by the specific exemptions of the VAT Act.

A checklist for the fourth quarter of 2026

If your 2026 turnover is above €800,000, you must issue e-invoices from 1 January 2027. What to have settled before then:

  1. 1Check your 2026 turnover. The prior year's total turnover decides: above €800,000 the obligation starts in January 2027, below it in 2028.
  2. 2Pick the format. XRechnung or ZUGFeRD in a profile that meets the European standard EN 16931. A plain PDF does not count.
  3. 3Align software and tax adviser. Can your ERP or accounting software issue and receive e-invoices? Plan the switch with your Steuerberater.
  4. 4Sort out archiving. For an e-invoice the structured part is the original and must be kept, not just a printout.
  5. 5Plan for the rest. Small-amount invoices, travel tickets, foreign supplier invoices and delivery notes keep arriving as PDFs or photos. Decide who captures them.

What still arrives as a PDF or a photo

Put together, these categories keep arriving the old way:

  1. 1Every supplier that chooses to wait, until the end of 2026 — and small suppliers, until the end of 2027.
  2. 2Receipts and small invoices behind expense claims: fuel, parking, meals, taxis and anything up to €250.
  3. 3Train and flight tickets for travel expenses.
  4. 4Invoices from *Kleinunternehmer* — freelancers and small tradespeople you buy from.
  5. 5Foreign supplier invoices, from Austria, Switzerland or anywhere else.
  6. 6Documents that are not invoices: delivery notes (Lieferscheine), quotes (Angebote) and purchase orders (Bestellungen), which never were in scope.

How to size what is left

Take the last 100 inbound documents your team processed and mark each one in the six categories above. In 2026 the answer for most companies is "most of them". After 2028 categories 2 to 6 remain — for a tradesperson's accountant, a construction company or a logistics business, that is still a large share.

Where WhappScan fits — and where it does not

WhappScan does not create, validate or send XRechnung or ZUGFeRD files, and it does not replace your e-invoicing software. For structured e-invoices, read the XML directly — that is what it is for.

WhappScan handles what arrives without structure: it reads invoices, receipts, delivery notes, quotes and purchase orders sent as a PDF or a photo and returns their fields — supplier, VAT ID, date, VAT, total, and each line where the document has them — ready for Excel or your accounting software. Staff and clients can send the photo by WhatsApp, with nothing to install.

Try it on your own documents: the invoice to Excel tool, the receipt to Excel tool and the delivery note tool are free, need no signup and handle up to three documents a day.

For every country side by side, see e-invoicing mandates country by country.

Sources

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