Germany is in the middle of the biggest change to its invoicing rules in decades. Since 1 January 2025, every German business — including the smallest Shopify store — must be able to receive structured electronic invoices. Between now and 1 January 2028, the obligation to issue them phases in for everyone.
If you sell to business customers in Germany, or you simply run a German business that buys anything at all, this affects you. Here is the timeline, what the formats actually are, and what to do about it — without panic.
The timeline at a glance
The mandate was introduced by the Growth Opportunities Act (Wachstumschancengesetz) of March 2024 and covers domestic B2B transactions — invoices between two businesses established in Germany.
| Date | What changes |
|---|---|
| 1 Jan 2025 | All German businesses must be able to receive e-invoices. The recipient's consent is no longer required for structured e-invoices. Already in force. |
| Until 31 Dec 2026 | Transition period: paper invoices and (with the recipient's consent) ordinary PDFs may still be issued by anyone. This window closes at the end of this year. |
| 1 Jan 2027 | Businesses with prior-year turnover above €800,000 must issue e-invoices for domestic B2B supplies. Smaller businesses keep transitional relief for one more year. |
| 1 Jan 2028 | E-invoice issuing becomes mandatory for all businesses in scope. EDI-based transitional arrangements also end. |
Two important carve-outs: small businesses using the Kleinunternehmerregelung are exempt from the obligation to issue e-invoices (they must still be able to receive them), and small-value invoices up to €250 are also excluded. B2C sales and cross-border transactions are not covered by this mandate — though the EU's ViDA package, adopted in March 2025, will make structured e-invoicing mandatory for intra-EU B2B transactions from July 2030.
What counts as an "e-invoice" now
This is the part that trips people up: since 2025, German law defines an e-invoice as an invoice in a structured electronic format conforming to the European standard EN 16931 — machine-readable XML that software can process without a human retyping anything.
A PDF is not an e-invoice. Neither is a scanned paper invoice, a JPEG, or an invoice pasted into an email. These are now legally sonstige Rechnungen ("other invoices"), tolerated only under the transitional rules described above.
Two formats dominate in Germany:
XRechnung
Germany's official implementation of EN 16931: a pure XML file (in UBL or CII syntax), maintained by KoSIT, the German coordination office for IT standards. It has been mandatory for invoicing federal public-sector customers (B2G) since 2020. It is machine-perfect and human-hostile — nobody reads raw XRechnung XML.
ZUGFeRD (Factur-X)
A hybrid format: a normal, human-readable PDF/A-3 with the EN 16931 XML embedded inside. Your customer's accountant sees a familiar PDF; their accounting software extracts the structured data automatically. ZUGFeRD from profile "EN 16931" upward satisfies the German mandate, and it is technically identical to France's Factur-X — one file, two countries covered.
For e-commerce, ZUGFeRD is usually the pragmatic choice: you keep sending customers a PDF they can open, and the same file is a legally valid e-invoice.
How e-invoices are exchanged
Unlike Italy (SDI) or France (accredited platforms), Germany has no central transmission platform — at least for now. An e-invoice can be delivered by email, download link, Peppol, or any channel the parties agree on. An email inbox is legally sufficient to meet the receiving obligation.
Note that receiving is only half the job: a received XML invoice must be archived in its original machine-readable form for the retention period (8 years for invoices since 2025, under GoBD conditions). Printing it out and filing the paper does not comply.
A ViDA-aligned transaction reporting system is expected to follow later in the decade, but no reporting obligation applies to domestic German B2B e-invoices today.
What this means for a Shopify merchant
Work through three questions.
1. Can you receive e-invoices? (Required since January 2025)
Your suppliers — your 3PL, your agency, your packaging vendor — may already send XRechnung or ZUGFeRD files. You must be able to accept them; you cannot demand paper. Practically: have a dedicated invoice email address, and make sure whatever you use for bookkeeping can read EN 16931 XML or at least archive it unchanged.
2. Do you sell B2B to German businesses?
If any of your Shopify customers are German businesses — wholesale buyers, corporate gifting, other retailers — you will be legally required to issue structured e-invoices to them: from 2027 if your turnover exceeded €800,000 last year, and from 2028 regardless of size. Shopify's native order confirmations and standard PDF invoice apps do not produce EN 16931 output, so this needs dedicated tooling.
Even before your own deadline, expect pull from the other side: large German business customers increasingly request e-invoices now, because their AP departments have already automated around them.
3. Only B2C? You still have homework
Pure consumer sales are outside this mandate — you can keep sending PDF invoices to consumers indefinitely. But you still fall under the receiving obligation for your purchases, and everything you issue must still meet the general German requirements: correct § 14 UStG content, traceable sequential numbering, and immutable archiving (see our GoBD guide). If there is any chance you will add B2B, choosing an invoicing setup that already outputs ZUGFeRD costs nothing extra today and removes a migration later.
A sensible action plan for mid-2026
- Receiving: confirm today that you can accept and archive XML e-invoices — this has been mandatory for a year and a half.
- Classify your customers: estimate what share of your revenue is domestic German B2B. That share defines your exposure to the 2027/2028 issuing deadlines.
- Check your turnover against the €800,000 threshold to know whether your issuing deadline is 1 January 2027 or 2028.
- Pick a format strategy: for a Shopify store, hybrid ZUGFeRD PDFs cover both human customers and the mandate; support XRechnung export for customers who ask for pure XML.
- Don't wait for the deadline. The transition period for issuing plain PDFs ends on 31 December 2026 for larger businesses. Merchants who switch now get to debug their process calmly instead of in January.
The mandate is, honestly, good news for well-prepared merchants: structured invoices mean fewer disputes, faster payment from B2B buyers, and cleaner bookkeeping. The only losers are those who ignore it until an important customer's AP system starts rejecting their PDFs.
Facturely generates audit-proof invoices for Shopify stores automatically — gapless numbering, ZUGFeRD/Factur-X hybrid PDFs and XRechnung export, ready for Germany's 2027/2028 deadlines out of the box.
This article is general information, not tax advice. For your specific situation, consult your Steuerberater or tax advisor.