Germany e-invoicing 2025–2028: what freelancers and Kleinunternehmer must do now

Germany’s e-invoicing mandate is the quietest of the big European ones: no platform to register with, no real-time reporting, just a change in what counts as an invoice and a three-step calendar. For a Freiberufler or a one-person GmbH the important part is that step one already happened.

What an e-invoice is in Germany

Under the Growth Opportunities Act (Wachstumschancengesetz), an “electronic invoice” is no longer any invoice sent electronically. It is a structured file that conforms to the European standard EN 16931, which a machine can read. Two formats dominate:

• XRechnung — pure XML, originally built for invoicing public authorities, now the reference format.
• ZUGFeRD (from version 2.x) — a normal-looking PDF with the XML embedded inside. Humans read the PDF, software reads the XML. This is the friendliest format for a one-person business, because your client can still open it like any invoice.

A plain PDF, a scan or a Word file is now a “different invoice” (sonstige Rechnung), allowed only during the transition and only with the recipient’s consent.

The three steps

Scope: transactions between two businesses established in Germany. Invoices to consumers and to foreign clients are outside the duty. Small-amount invoices (up to 250 euros) and tickets keep their simplified rules.

What a freelancer has to do, concretely

1. Receiving — already required. Legally, an email inbox that accepts an XML attachment satisfies the rule. Practically, you want a tool that opens the file, shows you the invoice, checks the XML, books it and archives it unchanged for the ten-year retention period. Every serious German accounting tool for the self-employed does this now; the shortlist for German freelancers is built around XRechnung and ZUGFeRD support. If a supplier sends you an XRechnung and you cannot read it, that is your problem, not theirs.

2. Issuing — 2028 for most solos, 2027 if you are big. The 800,000-euro line puts nearly every one-person business in the 2028 group. That does not mean wait: German corporate clients are already adopting e-invoicing for their own 2027 duty and increasingly ask suppliers for ZUGFeRD. Being able to send one on request is a small competitive courtesy and costs nothing if your tool supports it.

3. Kleinunternehmer — receive yes, issue no. If you are under the small-business rule you do not have to issue e-invoices even after 2028, but you must still accept them, and you may choose to issue them when a client prefers. If you plan to leave the Kleinunternehmer rule as you grow, you will land in the general regime anyway.

4. Foreign clients — unaffected by format, same VAT logic. An invoice to a client in Austria or the Netherlands is outside the German e-invoicing duty. It still needs the ordinary mandatory content and, for EU business clients, the reverse-charge note — see reverse-charge VAT explained and the general checklist in how to invoice clients as a freelancer in the EU.

The cheap way to be compliant

For a freelancer the whole mandate reduces to one decision: invoice and book from a tool that speaks XRechnung and ZUGFeRD. Then receiving is automatic, issuing is a checkbox when the date comes, and the archive rule is handled. If you are still setting up, the order of operations — tax number, VAT choice, Kleinunternehmer or not, bank, tool — is in registering as self-employed in Germany and the full toolkit in running a one-person business in Germany.

Germany is one square on a European board: the country-by-country map of formats and dates is in EU e-invoicing mandates by country.

The takeaway

• Receiving is mandatory now, for everyone, Kleinunternehmer included. An inbox is the legal minimum; a tool is the practical one.
• Issuing: 2027 above 800,000 euros, 2028 for the rest. Kleinunternehmer exempt from issuing.
• Domestic B2B only. Foreign and consumer invoices keep the normal rules.
• No platform, no live reporting. Pick a tool that produces ZUGFeRD and you are done.

Part of the EU admin guide for solopreneurs.