· Luca Moretti
A PDF is no longer an e-invoice: Germany’s deadlines, 2025 to 2028
Since January 2025 every German business must be able to receive e-invoices. Paper and PDF issuing ends on 31 December 2026 for most firms.
Since 1 January 2025, every business in Germany that receives an invoice from another German business must be able to receive and process it as an e-invoice. The sender no longer needs your consent to send one. Small invoices up to €250 gross, tickets and some tax-free sales are exempt.
What counts as an e-invoice
Under § 14 UStG a plain PDF is not an e-invoice. It is an “other invoice”. An e-invoice is a structured file that follows the European standard EN 16931. In practice that means one of two formats:
- XRechnung: pure XML, maintained by KoSIT in Bremen.
- ZUGFeRD (from version 2.0.1): a PDF with the XML embedded, readable by people and software.
The deadlines
- Receiving: mandatory since 1 January 2025.
- Sending paper or PDF: allowed until 31 December 2026.
- If your turnover last year was up to €800,000: until the end of 2027.
- Invoices to private customers still need their consent to be electronic.
Keep it for eight years
Invoices in Germany are now kept for eight years (§ 14b UStG; it was ten until 2025). With ZUGFeRD you archive the XML and the PDF, and the GoBD rules on unchangeable storage apply. France follows: all VAT-registered firms there must receive e-invoices from 1 September 2026.
What to do this quarter
Check that your accounting tool can create XRechnung or ZUGFeRD, decide where incoming XML lands, and test one invoice end to end with your tax adviser before January.