E-Invoicing Mandate 2025–2028: Timeline & To-Dos

The most important answer first: in Germany, the 2025 e-invoicing mandate initially only concerns receiving. Since 1 January 2025, every domestic company in the B2B space must be able to accept and process electronic invoices in a structured format. The obligation to issue e-invoices yourself arrives in stages: from 1 January 2027 for companies with more than 800,000 euros in prior-year revenue, and from 1 January 2028 for everyone. This timeline shows you, vendor-neutrally, which deadlines apply, which formats count and what you should prepare now — above all in your ERP system.

What the 2025 e-invoicing mandate actually means

An e-invoice in the legal sense is not a PDF file. A PDF is a pictorial representation and cannot be read cleanly by machines. What is meant is a structured data set in a defined format that allows automated processing without a media break. The legally decisive reference is the European standard EN 16931, which specifies which data fields an invoice must contain and how they are technically structured.

Important context: the mandate applies to domestic B2B transactions between companies established in Germany. Invoices to end consumers (B2C), small-value invoices up to 250 euros and certain tax-exempt transactions are exempt for now. Invoices to public-sector clients (B2G) have been subject to an e-invoicing mandate for some time already.

The 2025-to-2028 timeline at a glance

Lawmakers phase the obligations in over several years. The key is to cleanly separate receiving from issuing — this is where most misunderstandings arise.

The practical takeaway: since 2025 you can no longer rely on continuing to receive only PDFs. A supplier is already allowed to send you an e-invoice today, and you must be able to process it — regardless of your company size. Issuing invoices yourself is the second stage, which you must have ready by 2027 or 2028 depending on your revenue.

Which formats count: XRechnung, ZUGFeRD and Peppol

Within the EN 16931 standard, two formats have become established in Germany. Both are permitted — the choice depends on your processes and recipients.

XRechnung – the pure XML standard

The XRechnung is a purely structured XML data set with no visual component. It is the standard in the public-sector context (B2G) and can be processed directly by machines. Without suitable software, an XRechnung is barely readable for humans — and that is by design, because it is made for the machine.

ZUGFeRD – the hybrid format

ZUGFeRD combines both: it is a PDF/A-3 file with an embedded XML data set. Humans see the familiar invoice view, while software reads the structured XML. For the transition this is convenient, because the same file works for both automated and manual processing. From the "EN 16931" profile (also called "Comfort") onward, ZUGFeRD meets the legal requirements.

Peppol – the transmission channel

Peppol is not an invoice format but a secure European network for exchanging electronic documents via so-called access points. Many ERP and accounting systems use Peppol to send e-invoices in a standardized, cross-border way. The format (XRechnung/ZUGFeRD) and the transport channel (Peppol, email, portal) are two separate decisions.

What you should do right now

Even if your obligation to issue only kicks in for 2027 or 2028: receiving has been mandatory since 2025, and the switchover needs lead time. These steps belong on your to-do list.

• Secure receiving. Set up a defined inbound channel (e.g. a dedicated email address or a Peppol connection) and check whether your system can read XRechnung and ZUGFeRD.
• Check the revenue threshold. If your prior-year revenue exceeded 800,000 euros, your obligation to issue already applies from 2027 — not just from 2028.
• Clean up master data. Complete and correct master data is mandatory: routing IDs (Leitweg-IDs), tax numbers, IBAN, units and tax keys must be maintained cleanly, otherwise the e-invoice will be faulty.
• Test outbound invoicing. Generate test invoices in the target format and have them validated before the mandate applies.
• Sort out archiving. E-invoices are subject to the GoBD and must be retained in an audit-proof way in their original format — a printout is not enough.
• Document your processes. Record the new invoice workflow in your procedural documentation.

The role of the ERP system

At its core, the e-invoice is a data topic — and therefore an ERP topic. Because invoices arise from your orders, items and customer data. A modern ERP system generates the structured formats directly out of the order processing workflow, without you having to enter data twice.

For any candidate or your existing system, check three things: can it natively issue e-invoices in the EN 16931 format, can it automatically read and post incoming XRechnung/ZUGFeRD, and does it support the desired transmission channel (Peppol, email, portal)? Many systems cover this out of the box, others only via add-on modules or an interface to an invoicing service provider.

If you are facing a system decision anyway, it is worth a look at the ERP directory: commerce and cloud systems such as xentral, weclapp or Odoo treat the e-invoice as a standard feature today. For the technical connection to Peppol access points or accounting software, a clean integration helps — especially when your shop, shipping and financial accounting need to mesh cleanly. Use the ERP comparison to specifically assess candidates on their e-invoicing capabilities.

A look across the border: Austria and Switzerland

The German phasing does not automatically apply to the entire DACH region — anyone invoicing across borders has to differentiate.

• Austria: For deliveries to the federal government, an e-invoicing mandate via the USP portal or the Peppol network has been in place for years. A blanket B2B mandate like Germany's is, as of 2026, not in force in the same form — but the EU-wide "VAT in the Digital Age" (ViDA) initiative will continue to harmonize the topic in the medium term.
• Switzerland: As a non-EU country, Switzerland follows its own rules. In payment transactions the QR-bill dominates, having replaced the former payment slips. There is no EN 16931 obligation, but invoices to the federal public administration are issued electronically.

For specific deadlines in each country and your tax situation, your tax advisor is the right point of contact when in doubt — this article does not replace legal advice.

Conclusion

The 2025 e-invoicing mandate is not distant future music but has long been reality: you already have to receive structured invoices today. Issuing them yourself follows in stages in 2027 and 2028, depending on your prior-year revenue. Anyone who dismisses the switchover as a mere format problem underestimates it — in truth, master-data quality, posting processes and audit-proof archiving all hang on it. The pragmatic path: secure receiving now, check your ERP for native issuing and Peppol connectivity, and use the remaining transition time for clean tests. Then an obligation turns into an efficiency gain, because automated invoice processes permanently reduce effort and errors.