Germany's E-Rechnung Mandate: X-Rechnung, ZUGFeRD, and the 2025–2028 Timeline

Germany's Wachstumschancengesetz (Growth Opportunities Act, March 2024) made structured e-invoicing the default for domestic B2B transactions starting 1 January 2025. The mandate is staged: receive first, then issue, with smaller businesses given the longest runway.

Timeline

• 1 January 2025 — All businesses established in Germany must be able to receive structured e-invoices in EN 16931 format (X-Rechnung XML or ZUGFeRD hybrid PDF). Sending paper or PDF is still allowed during the transition.
• 1 January 2027 — Mandatory issuance for businesses with prior-year turnover above €800,000. Below that threshold, paper / PDF is still allowed by mutual agreement.
• 1 January 2028 — Mandatory issuance for all businesses regardless of size. From this date, paper and unstructured PDF are no longer permitted for domestic B2B.

X-Rechnung vs ZUGFeRD

X-Rechnung is a pure XML format defined by KoSIT (Coordination Office for IT Standards). It's mandatory for invoicing the German public sector and acceptable for B2B.

ZUGFeRD is a hybrid PDF/A-3 with embedded EN 16931 XML — the same idea as France's Factur-X. The two formats are technically aligned. ZUGFeRD 2.x and Factur-X are interchangeable.

Both X-Rechnung and ZUGFeRD comply with EN 16931, which is what the law requires.

What SMEs must do now

• Make sure you can receive X-Rechnung XML and ZUGFeRD PDF/A-3 — most modern accounting platforms (Hisabi included) handle this transparently.
• If your turnover is above €800,000 and you don't issue e-invoices today, plan to switch before 1 January 2027.
• Below the €800,000 threshold, you have until 1 January 2028 — but customers may ask for ZUGFeRD earlier and you'll want to be ready.
• Keep your VAT codes (USt-IDs) clean and validated against VIES; an invalid code blocks the EN 16931 schema.

Retention

Germany requires invoices and the underlying records to be retained for 10 years under § 147 Abgabenordnung (AO). The retention applies to both the visual representation and the structured XML; you need to be able to produce the original e-invoice on request, in unaltered form, for the full period.

How Hisabi helps

Hisabi exports ZUGFeRD 2.x PDF/A-3 for German invoices today, with the German narrative on the visual layer and EN 16931-compliant XML embedded. X-Rechnung XML export is on the roadmap for Q1 2027 — ahead of the issuance threshold for €800k+ businesses. Both formats include the German VAT-ID validation and reverse-charge logic for intra-EU B2B services.