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E-invoicing obligation 2025–2028 for online merchants: deadlines, exceptions and formats

Since 01.01.2025 domestic businesses must be able to receive e-invoices. From 2027 issuing becomes mandatory for businesses with more than €800,000 prior-year revenue, from 2028 for everyone, with exceptions. What this means for shop owners.

Updated: 7 minIron Saleh — Founder, NorthProfit

In short: an e-invoice is an invoice in a structured electronic format under the standard EN 16931; a simple PDF does not meet this definition. Since 01.01.2025 domestic businesses must be able to receive e-invoices. Transitional rules apply to issuing until the end of 2026 and the end of 2027 respectively. NorthProfit creates ZUGFeRD documents with embedded EN 16931 XML; check format, mandatory details and your specific tax case before productive use.

B2B, not B2C

The obligation applies to invoices between domestic businesses (B2B). Invoices to private end customers (B2C) are excluded. Clarify the exact use case with your tax advisor; this article is not tax advice.

The deadlines at a glance

E-invoice: deadlines and transitional rules (sources checked on 29.09.2026)
DateWhat appliesTo whom
since 01.01.2025Be able to receive e-invoices; an email inbox is enoughall domestic businesses, including small businesses
until 31.12.2026Paper invoices remain permitted; other electronic formats such as a PDF only with the recipient's consentall invoice issuers
until 31.12.2027Transition extended: still paper or, with consent, another electronic format; existing EDI procedures remain usableissuers with at most €800,000 prior-year revenue (decisive for 2027: revenue 2026); EDI for everyone
from 01.01.2027Issue e-invoices for domestic B2B salesbusinesses with more than €800,000 prior-year revenue
from 01.01.2028Issue e-invoices for domestic B2B salesall businesses, with the exceptions below

Exceptions from the issuing obligation

  • Small-amount invoices up to €250 gross (§ 33 UStDV) and tickets (§ 34 UStDV) may still be issued as an other invoice.
  • Small businesses under § 19 UStG are exempt from issuing but must be able to receive e-invoices.
  • Certain tax-exempt services are also exempt.
  • Invoices to private customers (B2C) are not covered by the e-invoicing obligation.

What counts as an e-invoice (and what does not)

What matters is the structured format under the EU standard EN 16931. Two formats are established in Germany:

  • XRechnung, a pure XML format (common in public procurement).
  • ZUGFeRD from version 2.0.1, a hybrid of PDF/A-3 and embedded XML. According to the BMF all profiles except MINIMUM and BASIC-WL meet the requirements.
  • For hybrid formats, the structured XML part has been decisive since 2025, not the readable PDF.
  • A normal PDF or a scan is not an e-invoice: the structured data record is missing.
NorthProfit creates ZUGFeRD

NorthProfit can create invoices as a ZUGFeRD hybrid with embedded XML in the EN 16931 profile (COMFORT). A technical format check and a check of the mandatory tax details remain necessary before sending.

What you should do now as a shop owner

  1. Ensure receipt: an inbox that accepts e-invoices (XML/ZUGFeRD) and a traceable, unchangeable archiving process.
  2. Switch outgoing invoices to business customers to an e-invoice format (ZUGFeRD or XRechnung) before the obligation applies to you.
  3. Clarify with your tax advisor whether the issuing obligation applies to your sales from 2027 (prior-year revenue 2026 above €800,000) or only from 2028.
  4. Retain e-invoices: according to the BMF at least the structured part must be kept intact in its original form for eight years.

Plan the handover to accounting right away: incoming and outgoing invoices should reach your firm with their structured part so that receipts do not have to be captured twice.

Frequently asked questions

As an online merchant, do I have to send e-invoices to private customers?
No. The e-invoicing obligation concerns sales between domestic businesses (B2B). Invoices to private customers are not covered.
From when must my shop issue e-invoices?
For domestic B2B sales from 01.01.2027 if your prior-year revenue 2026 was above €800,000, otherwise from 01.01.2028. Until the end of 2026 paper invoices are permitted, other electronic formats such as a PDF only with the recipient's consent.
Is a PDF sent by email an e-invoice?
No. A PDF without a structured data record is an other invoice. ZUGFeRD combines PDF and XML; the XML part is decisive.
Is an email inbox enough for receiving?
Yes. According to the BMF an email inbox is enough for receiving. You still have to retain the e-invoices received properly.

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