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E-invoicing mandate for hosting providers and stores
Deadlines, formats and a practical five-step plan.
Germany has been rolling out mandatory e-invoicing for domestic B2B business since 2025, staged by receiving and sending. For hosting providers, agencies and online stores that sell to businesses, this means structured e-invoices by 2028 at the latest. Here are the deadlines, formats and a practical way to comply.
Deadlines
| From | What applies |
|---|---|
| 1 January 2025 | All German businesses must be able to receive e-invoices. An email inbox is technically enough. |
| until 31 December 2026 | All issuers may still use paper or other invoices; PDF only with the recipient's consent. |
| 1 January 2027 | Businesses with more than €800,000 total turnover in the previous year (2026) must issue e-invoices for domestic B2B sales. |
| until 31 December 2027 | Businesses up to €800,000 prior-year turnover may use other invoices for the last time. |
| 1 January 2028 | The obligation to issue applies to all domestic B2B sales, regardless of turnover. |
The legal basis is sections 14 and 27 of the German VAT Act as amended by the Growth Opportunities Act, plus the FAQ of the Federal Ministry of Finance. Always check the ministry's current guidance.
Who is affected – and who is not?
It covers invoices between German businesses (B2B). Invoices to consumers (B2C) are not covered. Permanently exempt are, among others, small-amount invoices up to €250 and travel tickets. Small businesses under section 19 of the VAT Act do not have to issue e-invoices, but like everyone else they must be able to receive them.
In practice: a game server host selling mostly to consumers is barely affected; an agency or a business hosting provider is.
Which formats count?
An e-invoice is a structured data format under the European standard EN 16931. A PDF on its own is not an e-invoice. Two formats are common in Germany:
- XRechnung – pure XML, standard for public-sector clients.
- ZUGFeRD (version 2.0.1 or later) – a PDF with embedded XML, readable by people and machines. The MINIMUM and BASIC-WL profiles are not sufficient.
For most small businesses ZUGFeRD is the pragmatic choice: the recipient sees a normal invoice, and accounting can import the data automatically.
Five steps to comply
- Receiving: define an inbox for incoming e-invoices and keep the original XML unchanged (eight years).
- Master data: complete company details, tax or VAT ID, bank details and customer data are the most common source of errors.
- Choose a format: ZUGFeRD for most customers, XRechnung where customers require it.
- Update your software: your billing system must produce the format – ideally automatically for every invoice.
- Test: check sample invoices with a validator and agree the setup with your tax adviser.
E-invoices with Paymenter
Paymenter creates PDF invoices out of the box, but not EN 16931 e-invoices. Our extension Faktora adds exactly that: XRechnung and ZUGFeRD straight from Paymenter, plus SEPA payments – without changes to the Paymenter core.
Note: this article is a technical overview, not tax advice. Please talk to your tax adviser about your specific case.
Frequently asked questions
No. An e-invoice is a structured format under EN 16931, such as XRechnung or ZUGFeRD. A plain PDF counts as an other invoice.
No. The mandate covers invoices between German businesses (B2B).
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