Invoicing Germany: E-Invoicing Becomes the Standard from 2027

Germany is the most important export market for Czech entrepreneurs. And that's exactly where one of the biggest changes in invoicing in recent years is under way: a gradual transition to mandatory structured electronic invoicing in B2B. Since 1 January 2025, every German company must already be able to receive an e-invoice, and from 1 January 2027 a large part of German companies will also be required to issue e-invoices. Six months remain before the next phase starts, and anyone invoicing into Germany should know what applies to them and what doesn't.
The Deadlines That Apply in Germany
The German mandate runs in three phases, summarised in the official European Commission overview of e-invoicing in Germany:
📋Phases of Germany's Mandatory E-Invoicing
During the transition period there is still a safety valve: according to the European Commission overview, a supplier may issue a paper invoice or an EDI invoice outside the EN 16931 standard if the customer agrees. In practice, however, large German customers will not be giving that consent, because they need structured data for their own automated processing.
What Germany Recognises as an E-Invoice
An electronic invoice in the German sense is not a PDF attached to an e-mail. The recognised formats are XRechnung (a pure XML file, the national standard), the hybrid ZUGFeRD 2.1 (a PDF with embedded XML, compliant with EN 16931), and Peppol BIS Billing 3.0. The common denominator is always the European standard EN 16931, in other words a machine-readable data message.
Does the German Obligation Apply to a Czech Supplier?
Legally speaking, the German mandate is built on domestic B2B transactions, that is, supplies between companies established in Germany. If you are a Czech OSVČ (self-employed person) or an s.r.o. (limited company) without a permanent establishment in Germany and you invoice a German customer cross-border, German law does not directly require you to issue an XRechnung.
In practice, though, that's only half the answer. It won't be the legal text that decides, but the customer:
- German companies, because of their own obligation, are rebuilding their entire processing of incoming invoices around structured data. An invoice that someone has to retype manually from a PDF will be an expensive exception for them.
- Larger customers are already adding a requirement for e-invoices in a specific format to their contracts and purchase order terms, typically XRechnung or ZUGFeRD, or delivery via the Peppol network.
- Anyone who can't deliver a structured invoice risks longer approvals, later payments, and in the worst case the customer finding a supplier who is less work to deal with.
On top of that comes the European dimension. The ViDA directive, adopted in March 2025, introduces, according to the European Commission, mandatory structured e-invoicing and digital reporting for cross-border B2B transactions within the EU from 1 July 2030. That will directly affect Czech VAT payers as well. The German mandate is therefore just the vanguard of what will apply to every invoice into the EU in a few years. We covered ViDA and the Peppol network in more detail in the article Peppol and E-Invoicing: What Awaits Czech Entrepreneurs.
How the German Formats Differ
📊E-Invoice Formats Recognised in Germany
For a Czech supplier, this yields a simple recommendation: ask your customer which format and which delivery channel they prefer. The answer will vary with the size of the company and its systems. The hybrid ZUGFeRD tends to be the most manageable first step, because on the outside it looks like an ordinary PDF.
What to Watch Out for as a Czech Supplier This Year
📋Preparing for Invoicing into Germany after 1 January 2027
Watch Out for the EC Sales List
Invoicing into Germany also has a Czech tax dimension that already applies today: supplies of goods and services to persons registered for VAT in another member state are reported in the EC Sales List (souhrnné hlášení) under § 102 of the VAT Act. The transition to e-invoicing changes nothing about this; it only raises the bar for the data in your invoices and reports to match to the last koruna.
Conclusion
Germany's mandatory e-invoicing won't reach Czech suppliers through the law, but through purchase orders. From January 2027, large German customers will start invoicing exclusively in structured form and will gradually demand the same discipline from their suppliers, and from 2028 the entire German market will. Anyone who already keeps invoices and receipts in a digital, structured form will handle the transition to XRechnung, ZUGFeRD, or Peppol as a technical detail. Anyone still relying on paper and manual retyping should start now, while there is time for a calm changeover.
Want your receipts and invoices in digital form without manual retyping? Try DokladBot: photograph a document, the data is extracted automatically, and your records are ready for your accountant and for future structured invoicing.
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