E-invoicing in Germany 2027: what it means for your webshop

E-invoicing in Germany 2027 for webshops: the short answer

Germany is phasing in mandatory B2B e-invoicing. Since 1 January 2025 every German business must be able to receive e-invoices. From 1 January 2027 businesses with more than €800,000 turnover in the previous year must issue them, and from 1 January 2028 everyone must. An e-invoice here means structured data under EN 16931, typically XRechnung or ZUGFeRD, not a PDF.

For webshops the key question is scope. The rules apply when both seller and business buyer are established in Germany. A German webshop selling to German companies is in scope. A store based in Romania, the Netherlands or the UK with no German establishment is not legally in scope, although German buyers' accounts teams will increasingly ask for e-invoices anyway.

We checked these rules on 24 October 2026 against the German Federal Ministry of Finance (BMF) letters and the VAT Act. This is not tax advice. Confirm your own situation with your accountant or a German tax adviser.

Why it matters: the legal basis and the timeline

The mandate was introduced by the Growth Opportunities Act (Wachstumschancengesetz) of 27 March 2024, which rewrote § 14 of the German VAT Act (UStG). The transition rules are in § 27(38) UStG. The BMF has explained how to apply them in three letters: 15 October 2024, 15 October 2025 and, most recently, 15 October 2026.

Date	Receiving	Issuing	What a German B2B webshop may send
1 Jan 2025 – 31 Dec 2026	Mandatory for all German businesses	Not yet mandatory	E-invoice, PDF or paper (other electronic formats need the buyer's consent)
1 Jan 2027 – 31 Dec 2027	Mandatory	Mandatory if previous-year turnover was above €800,000	Below the threshold: paper or, with consent, PDF. EDI with consent for everyone
From 1 Jan 2028	Mandatory	Mandatory for all	E-invoice (EDI only if it meets the e-invoice requirements)

The €800,000 test uses the issuer's total turnover in the previous calendar year, so 2026 turnover decides whether you must issue e-invoices for supplies made in 2027.

Who is in scope, and who is not

The BMF guidance in the amended VAT Application Decree (UStAE, section 14.1) is clear on the basic rule. An e-invoice is required when the customer buys for their business and both the supplier and the customer are established in Germany: registered office, management, or a VAT fixed establishment involved in the supply. If at least one of them is not established in Germany, there is no e-invoice obligation, and the invoice can be on paper or, with consent, in another electronic format.

Other exclusions that matter to online stores:

• B2C sales. Consumers are outside the mandate. Sending them an e-invoice requires their consent.
• Small invoices. Invoices whose total does not exceed €250 (Kleinbetragsrechnungen) can always be sent as other invoices.
• Small businesses under § 19 UStG (Kleinunternehmer) may keep issuing other invoices, but must still be able to receive e-invoices.

"I didn't know the customer was a business"

This matters to webshops with a mixed customer base. According to the BMF, a missing e-invoice is not challenged if the seller did not know, and could not have known with ordinary commercial care, that the buyer was a business. The BMF names the use of a VAT ID as an indicator that the buyer is acting as a business. In practice: if your checkout collects a VAT ID, you know.

What happens if you send the wrong format

The October 2026 BMF letter states that issuing an other invoice where an e-invoice was required is not an administrative offence under § 26a UStG. That does not make it risk-free. Your buyer's input VAT deduction depends on a proper invoice, so German accounts payable teams will reject PDFs once the obligation applies. Expect payment delays rather than fines.

What German customers will ask you for

Even where the law does not oblige you, German buyers' accounts payable teams set the practical standard. Expect these requests from German B2B customers from 2027 onwards:

• An XRechnung or ZUGFeRD file instead of, or alongside, the PDF.
• Their purchase order number and a buyer reference on every invoice.
• Delivery to a dedicated invoice inbox or upload to their supplier portal.
• Credit notes for returns in the same structured format as the original invoice.
• Your VAT ID, their VAT ID and the correct reverse-charge wording on intra-EU supplies.

A store that can deliver these without manual work becomes the easier supplier to buy from, which matters when a German buyer compares you with a domestic competitor.

Options: which format, and how to produce it

XRechnung or ZUGFeRD?

	XRechnung	ZUGFeRD (2.0.1 or later)
What it is	Pure XML, the German CIUS of EN 16931	Hybrid PDF/A-3 with embedded XML (technically equivalent to Factur-X)
Human-readable	Only with a viewer	Yes, it is a normal PDF
Syntax	UBL or UN/CEFACT CII	CII
Valid profiles	Standard XRechnung, plus conformant extensions	BASIC, EN 16931 (COMFORT), EXTENDED and XRECHNUNG; not MINIMUM or BASIC-WL
Typical recipients	Public sector, large corporates	SMEs that still want a readable PDF
Maintained by	KoSIT	FeRD

The BMF confirms that XRechnung meets the requirements and that ZUGFeRD from version 2.0.1 does too, except for the MINIMUM and BASIC-WL profiles, which lack mandatory invoice data. The format is a matter of contract between you and your customer. There is no central government platform and no Peppol obligation in Germany: email, a download portal, EDI or an API all count as transmission channels.

Where the e-invoice should come from

Approach	When it is enough	Limits
WooCommerce plugin for the German market	A German webshop with simple B2B orders	Quality varies; check EN 16931 validation, credit notes and the mapping of discounts and shipping
Accounting or invoicing software (Lexware Office, formerly lexoffice; sevDesk; DATEV-connected tools)	The shop sends orders, the accounting tool issues the e-invoice	Two systems to keep in sync; returns often handled by hand
ERP (Business Central, SAP and others)	You already invoice from an ERP	The webshop-to-ERP order sync must be reliable and fast
Custom invoicing service	Several entities, marketplaces, B2B price lists or high volumes	Development and maintenance cost

Be honest with yourself about volume. A German store issuing 20 B2B invoices a month can use a decent plugin or accounting tool. A group selling across several shops and marketplaces with customer-specific prices usually needs invoices generated from one place, normally the ERP.

Step by step: getting your webshop ready

1. Classify your German B2B flows

• List the legal entities that invoice German customers, and where each one is established.
• Check whether any of them has a German VAT fixed establishment that takes part in the sales (warehouse staff, local sales team). Ask your adviser; a warehouse alone is not automatically a fixed establishment.
• Work out each German entity's 2026 total turnover to know whether 2027 or 2028 is your deadline.
• Count how many German B2B invoices exceed €250.

2. Make the checkout tell businesses from consumers

• Add a "buying as a business" option with company name and VAT ID.
• Validate VAT IDs against VIES before invoicing.
• Store a buyer reference or purchase order number field. Public-sector buyers require the BT-10 Buyer reference (Leitweg-ID) in XRechnung, and many corporates expect their PO number.
• Capture an invoice email address separate from the order contact; accounts payable inboxes are often different.

3. Map your data to EN 16931

E-invoices fail on data, not on law. The usual suspects in a webshop:

• Gross prices. WooCommerce often stores prices including VAT, while EN 16931 calculates from net amounts. Rounding differences break business rules such as BR-CO-15 (total with VAT must equal total without VAT plus VAT). The October 2026 BMF letter acknowledges this problem: for EN 16931 e-invoices based on gross prices and issued until 31 December 2027, the structured part may contain only the totals per VAT rate, provided an embedded human-readable attachment carries the itemised description.¹
• Discounts and coupons need to be document-level or line-level allowances, not negative lines without a VAT category.
• Shipping needs its own VAT category and rate.
• Description of goods must identify what was supplied. The 2026 letter says the structured part must make the type, quantity and nature of the supply clear enough to check the VAT treatment.
• Credit notes. If an e-invoice was required, the correction must also be an e-invoice, using a correction invoice type.

Validate every format before going live. KoSIT publishes an open-source validator with the official XRechnung rules, and most invoicing tools show validation results per document.

4. Set up receiving, too

Your German entity must already be able to receive e-invoices from suppliers. An ordinary email inbox is enough; you do not need a dedicated address. You do need a way to read XML, archive it unchanged for the retention period and get it into accounting.

5. Plan beyond 2028

Germany has signalled that a transaction reporting system may follow the e-invoicing mandate, so expect further changes. At EU level, the ViDA package (Council Directive (EU) 2025/516) moves intra-EU B2B transactions to e-invoicing and digital reporting from 1 July 2030. If you are building invoicing now, choose EN 16931 structured data as your internal standard, because that is where every EU country is heading.

Common mistakes we see

• Treating a nicely formatted PDF as an e-invoice.
• Generating ZUGFeRD in the BASIC-WL or MINIMUM profile because it was the plugin default.
• Losing the original XML by letting the accounting tool convert it to PDF before archiving.
• Issuing invoices from both the shop and the ERP, with duplicate numbers.
• Ignoring returns: the refund goes out, the credit note does not.

What it costs

Situation	What is involved	Cost (estimate)
Non-German store selling B2B into Germany	Optional e-invoice output as a service to customers, VAT ID capture, PO fields	Small add-on to an existing store; often a few days of work
German WooCommerce store, simple B2B	Plugin or accounting connector, EN 16931 mapping, validation, credit notes	A fixed-price module on a Launch build (Launch from €3,900 excl. VAT)
Store plus ERP, several channels	Orders into the ERP, e-invoices from the ERP, receiving flow	Enterprise, custom quote
Custom invoicing service	Discovery workshop, specification, phased build with fixed quotes	Fixed quote after the paid discovery workshop

Hosting and maintenance, including updates when formats change (KoSIT updates XRechnung regularly), start from €89/month. For anything beyond a plugin, we start with a free 30-minute call, then a paid discovery workshop that produces a specification and a fixed quote. See custom software and pricing, or book the free call.

How we did it for xcrm

xcrm is not an e-invoicing project, but it solves the underlying problem: one ERP as the source of truth for orders and invoices across several companies and shops. From the xcrm case study:

• Several companies in the group share one ERP; the CRM sits on top of Business Central.
• Sales teams get fast access to Business Central items, orders, invoices, stock and vendors.
• Webshop orders are pushed to Business Central automatically, so online orders reach the ERP without re-keying.
• Microsoft 365 mail and Planner are integrated, and an AI assistant answers questions about customers, products and orders.
• The result is one place for sales, marketing and operations data.

When orders reach the ERP automatically, issuing a compliant XRechnung or ZUGFeRD becomes largely an ERP configuration and mapping task rather than a webshop rebuild. That is the architecture we recommend to anyone selling B2B into Germany.