Receiving obligation is already in force
Since 1 January 2025, all German businesses — including freelancers — must be able to receive e-invoices in XRechnung or ZUGFeRD format. If a German B2B client sends you one, you cannot refuse it.
The full timeline
1 January 2025
Receiving obligation — all businesses
Every German business must be able to receive and process structured e-invoices (XRechnung or ZUGFeRD). If a supplier or client sends you an e-invoice, you must accept it. You cannot require them to send a PDF instead.
Until 31 Dec 2026
Transitional period — sending PDF is still allowed
PDF invoices and paper invoices remain valid for B2B transactions during this period, with the recipient's implicit or explicit consent. Most businesses accept PDF by default. You do not need to send XRechnung or ZUGFeRD yet.
1 January 2027
Sending obligation — large businesses (>€800k turnover)
Businesses with annual turnover above €800,000 in 2026 must send structured e-invoices for all domestic B2B transactions. For most freelancers this threshold is not yet relevant — but your large corporate clients will be sending you e-invoices from this date.
1 January 2028
Sending obligation — all businesses
All German businesses, regardless of size, must send structured e-invoices for domestic B2B transactions. This includes freelancers, Kleinunternehmer, and sole traders. From this date, PDF-only invoices for B2B are no longer compliant.
What is a structured e-invoice?
An e-invoice (E-Rechnung) under the German mandate is not a PDF sent by email. A PDF is a human-readable image of an invoice — there is no structured data a computer can extract from it automatically.
A structured e-invoice contains machine-readable data — invoice number, amounts, VAT, IBAN, dates — in a standardised format that accounting software can process without human re-entry. This is the core of what the mandate requires.
What counts as a structured e-invoice
XRechnung
Pure XML file. No human-readable component. Required for invoicing German public authorities (B2G). Standard for large corporate-to-corporate invoicing.
ZUGFeRD (v2+)
A standard PDF with structured XML data embedded inside it. Looks like a normal PDF but contains machine-readable invoice data. The most practical format for freelancers — readable by humans, processable by machines.
Factur-X
The French/EU equivalent of ZUGFeRD — technically identical at the data level. A ZUGFeRD invoice and a Factur-X invoice use the same underlying standard (EN 16931).
Both XRechnung and ZUGFeRD comply with the European standard EN 16931, which is the technical backbone of the EU's e-invoicing push (the ViDA directive — VAT in the Digital Age).
Who is affected — and who is not
The mandate applies to B2B transactions between German businesses that are registered for VAT purposes in Germany. Several important exceptions apply:
| Situation | E-invoice required? |
|---|---|
| German freelancer → German business client (B2B) | Yes — from 2028 for sending; receive from 2025 |
| German freelancer → private individual (B2C) | No — PDF / paper remains valid indefinitely |
| German freelancer → client outside Germany | No — cross-border transactions excluded |
| German freelancer as Kleinunternehmer (§19 UStG) | Must receive from 2025; must send from 2028 |
| Invoice under €250 (Kleinbetragsrechnung) | Exempt — simplified invoices remain valid |
| Train tickets, receipts, toll receipts | Exempt — these are not commercial invoices |
| Invoicing German public sector (B2G) | XRechnung already mandatory since 2020 |
What freelancers need to do right now
The 2025 receiving obligation sounds alarming, but for most freelancers the practical impact in the short term is minimal. Here is what actually matters:
Now (2025–2026)
- Ensure you can receive e-invoices — an email inbox is sufficient for ZUGFeRD PDFs. If a supplier sends you an XRechnung XML file, you need to be able to open and read it (free tools like Mustangproject.eu or Quba Viewer exist for this).
- Check whether any of your suppliers or clients have already switched to ZUGFeRD. Most have not yet, but large corporates are moving first.
- You do not need to send e-invoices yet. PDF invoices remain valid for B2B until end of 2026.
2026 preparation
- Evaluate invoicing software that supports ZUGFeRD output (Fastbill, Lexoffice, Sevdesk, and others already support it).
- If you invoice more than ~10 business clients, consider moving to software that generates ZUGFeRD automatically rather than building a manual workaround.
- Kleinunternehmer: you have the same deadlines but less urgency — most of your clients are unlikely to demand e-invoices until 2028.
From 2027–2028
- Large clients will start requiring e-invoices from you from 2027 if they exceed the €800k threshold.
- From 1 January 2028, all B2B invoices to German clients must be in XRechnung or ZUGFeRD format. PDF-only is no longer compliant.
- ZUGFeRD is the likely default for most freelancers — it looks like a PDF but contains the required embedded XML.
ZUGFeRD or XRechnung — which should you use?
For most freelancers, ZUGFeRD is the right choice. Here is why:
ZUGFeRD looks like a normal PDF
Your client can open it in any PDF reader, read it, print it, file it. The embedded XML is invisible to them but processable by their accounting software. No disruption to your current workflow — you just need software that generates ZUGFeRD instead of a plain PDF.
XRechnung is for public sector invoicing
If you invoice a German government agency, municipality, or public body, XRechnung is what they require. This has been mandatory for B2G invoicing since 2020. For private business clients, ZUGFeRD is generally preferred.
Both comply with EN 16931
Both formats meet the EU standard and both comply with the German mandate. A client's accounting system that accepts one will almost certainly accept the other. The choice is primarily about readability — ZUGFeRD wins for human-readable, XRechnung wins for pure machine processing.
What about ZUGFeRD profile levels?
ZUGFeRD has several profile levels — MINIMUM, BASIC, EN 16931 (Comfort), and EXTENDED. For standard freelance invoicing, the EN 16931 (Comfort) profile is the right default. It contains all required fields for the mandate and is supported by all major German accounting packages.
What this means for Kleinunternehmer
If you are a Kleinunternehmer under §19 UStG — meaning you do not charge VAT because your revenue is below €22,000 — the e-invoicing mandate still applies to you, but with nuance.
The mandate was introduced as a VAT compliance measure — structured data helps the Finanzamt cross-check VAT declarations automatically. Kleinunternehmer invoices carry no VAT, which reduces the immediate pressure on enforcement. In practice, most Kleinunternehmer's business clients will not start demanding XRechnung or ZUGFeRD until the 2028 deadline forces the issue.
The receiving obligation from 2025 does apply: if one of your suppliers sends you a ZUGFeRD invoice, you must accept it. But since most Kleinunternehmer's supplier base is also small freelancers, this is unlikely to arise often in 2025–2026.
Practical advice for Kleinunternehmer: Do nothing urgent right now. Monitor your business client requests — if a large client asks you to switch to ZUGFeRD, evaluate invoicing software then. You have until 2028 to comply with the sending obligation.
Frequently asked questions
Does the German e-invoicing mandate apply to freelancers?
Yes. From 1 January 2025, all VAT-registered businesses in Germany — including freelancers — must be able to receive structured e-invoices (XRechnung or ZUGFeRD). The obligation to send e-invoices follows later: large businesses from 2027, all businesses from 2028.
What is the difference between XRechnung and ZUGFeRD?
XRechnung is a pure XML file — no human-readable component. It is the standard format for invoicing German public authorities. ZUGFeRD is a hybrid format: a standard PDF with structured XML data embedded inside it. Both are accepted under the German e-invoicing mandate. ZUGFeRD is generally more practical for freelancers because it is readable by humans and machines.
Does the e-invoicing mandate apply to Kleinunternehmer?
The receiving obligation from 2025 applies to all businesses, including Kleinunternehmer. The sending obligation from 2028 also applies to all B2B transactions. In practice, most Kleinunternehmer will face little pressure from clients to send structured e-invoices until 2028.
Is a PDF invoice still legal in Germany after 2025?
For now, yes — with transitional rules. Until 31 December 2026, PDF invoices remain valid for B2B transactions. From 2027, large businesses must send structured e-invoices. From 2028, all B2B invoices must be in a structured format. PDF invoices to private individuals (B2C) remain valid indefinitely.
What do I need to do as a freelancer in 2025?
Primarily: ensure you can receive e-invoices. For ZUGFeRD, any email inbox and standard PDF reader is sufficient. For XRechnung XML files, a free viewer (Mustangproject.eu or Quba Viewer) is enough for now. You do not need to send e-invoices yet.
Does the mandate apply to invoices for private clients?
No. The e-invoicing mandate applies only to B2B transactions between German VAT-registered businesses. Invoices to private individuals — wedding photography, private coaching, consumer services — are not affected. PDF and paper invoices for B2C remain valid indefinitely.
What is ZUGFeRD and how do I generate it?
ZUGFeRD is a hybrid e-invoice format: a standard PDF with embedded XML. Major German invoicing tools — Lexoffice, Fastbill, Sevdesk, Billomat — already support ZUGFeRD generation. If you use a simple PDF invoice generator today, you will need to switch to one of these tools before 2028 (sooner if large clients ask earlier).
Does this connect to the EU VAT in the Digital Age (ViDA) directive?
Yes. Germany's national mandate is part of a broader EU push — the ViDA (VAT in the Digital Age) directive — which aims to make real-time digital VAT reporting mandatory across the EU by 2030. Germany is moving ahead of the EU-wide deadline with its own national rollout.
Related guides
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