E-Invoicing for Freelancers in Germany: Your 2025–2028 Action Plan
German freelancers and Einzelunternehmer: what you must do now, when you must start sending e-invoices, and which tools won't break your budget.
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E-Invoicing for Freelancers in Germany: Your 2025–2028 Action Plan
If you're a freelancer, sole trader, or Kleinunternehmer in Germany and you've been ignoring the e-invoicing mandate because it sounds like a large-company problem — it isn't. You are affected. The question is just how and when.
The good news: the requirements on your side are more modest than you might think, and there are free tools that handle this without drama. The bad news: the receiving obligation kicked in on 1 January 2025, so if you've been turning away or ignoring e-invoices since then, you may need to update your processes to become compliant.
Let's fix that.
What Changed on 1 January 2025
Germany's e-invoicing mandate, introduced via the Wachstumschancengesetz (Growth Opportunities Act) and anchored in §14 UStG, creates two separate obligations:
- Receiving obligation (Empfangspflicht) — effective 1 January 2025, all VAT-registered German businesses, including Freiberufler and Einzelunternehmer, must be technically capable of receiving structured e-invoices in XRechnung or ZUGFeRD format.
- Sending obligation (Ausstellungspflicht) — phased in over 2027 and 2028 depending on your revenue.
These obligations apply to B2B transactions between domestic (German) VAT-registered businesses. Invoices to private individuals (B2C) and invoices to customers in other countries are not affected.
The Receiving Obligation: You Must Act Now
Since January 2025, if a business client sends you a ZUGFeRD or XRechnung file, you cannot legally refuse to accept it or ask them to re-send it as a PDF instead. You need a way to receive, open, and archive it.
What "receiving" technically requires:
- An email inbox or portal where the file can land (email is fine — no special EDI infrastructure needed)
- The ability to open and read the structured format
- Compliant GoBD archiving — the original XML must be retained, not just a printed version
The BMF has confirmed that simply having an email address is sufficient as a delivery channel. What you actually need is a way to process and archive the XML content correctly.
Free ways to handle received e-invoices:
- Mustangproject Validator (mustangproject.org) — open-source, free, lets you view and validate ZUGFeRD/XRechnung files
- Kostenloser ZUGFeRD-Viewer from Factur-X — browser-based, no install needed
- Most modern accounting apps (sevDesk, lexoffice, easybill, DATEV) can import and display these files natively
If you're using a spreadsheet to track invoices, the 2025 receiving obligation is a genuine forcing function to move to proper software.
When Must Freelancers Start Sending E-Invoices?
Here's the phased timeline for the sending obligation:
| Deadline | Who is affected |
|---|---|
| 1 January 2025 | Receiving mandatory for all |
| 1 January 2027 | Sending mandatory for businesses with >€800,000 revenue in the prior year |
| 1 January 2028 | Sending mandatory for all remaining businesses (including those under €800k) |
So if you're a typical freelancer earning €50,000–€300,000 per year, your hard deadline for issuing e-invoices is 1 January 2028. That gives you time, but not infinite time, and getting set up now means two years of smooth operation before the deadline rather than a last-minute scramble.
One more thing: even before your mandatory sending date, any client can ask you to send an e-invoice, and you can agree to do so voluntarily. Larger clients are increasingly requesting this.
What About Kleinunternehmer (§19 UStG)?
If you operate under the Kleinunternehmerregelung — meaning your revenue was under €22,000 last year and won't exceed €50,000 this year — you don't charge VAT on your invoices. Does that exempt you from e-invoicing?
Partially, but not entirely.
- Receiving obligation applies to you. Even as a Kleinunternehmer, if a VAT-registered German client sends you a structured e-invoice (e.g., for a service they provide to you), you must be able to receive it.
- Sending obligation: You are not required to issue e-invoices to clients, because your invoices don't include VAT. However, the transition provisions allow — but do not yet require — Kleinunternehmer to send e-invoices voluntarily. You can continue sending PDFs until at least 2028.
- Important nuance: If a client requests an e-invoice from you, even as a Kleinunternehmer, you may choose to comply. Some software supports issuing ZUGFeRD invoices that correctly reflect the §19 exemption.
In practice: as a Kleinunternehmer, your immediate priority is receiving capability. Sending can wait.
Which ZUGFeRD Profile Do Freelancers Need?
ZUGFeRD comes in several profiles, each carrying a different amount of invoice data:
| Profile | Use case |
|---|---|
| MINIMUM | Very basic, for internal use — not suitable for sending to clients |
| BASIC WL | Line-item invoice without tax breakdown — limited use |
| BASIC | Full invoice with tax details — acceptable for most B2B scenarios |
| EN 16931 | Full EN 16931 compliant — the standard profile |
| EXTENDED | Additional fields for complex invoicing |
| XRECHNUNG | The public sector / large enterprise standard |
For freelancers sending invoices to business clients, ZUGFeRD EN 16931 (also called the Comfort profile in older versions) is the right choice for most cases. It maps to the European standard EN 16931 and is accepted by virtually all compliant software.
If you're billing government clients, public authorities, or large corporates who specify XRechnung, you need XRechnung specifically — a pure XML format without the PDF wrapper.
Most modern German invoicing tools generate both automatically.
Best Tools for Freelancers
You don't need enterprise software. These tools are built for small businesses and freelancers specifically.
sevDesk — Best Overall for Freelancers
sevDesk is the most widely used cloud accounting tool among German freelancers. It handles ZUGFeRD and XRechnung generation natively, links to your DATEV tax advisor, and has a clean interface that doesn't require accounting knowledge to operate.
What it does well:
- Creates ZUGFeRD (EN 16931) and XRechnung invoices out of the box
- Automatically embeds the XML in the PDF
- Receives incoming e-invoices and parses them
- GoBD-compliant archiving included
- DATEV export for your Steuerberater
Pricing: From €13.90/month (S plan, up to 15 invoices/month) — sufficient for most freelancers. Larger plans from €22.90/month.
Read our full sevDesk review for a detailed breakdown.
easybill — Best for Invoice-Heavy Freelancers
easybill is purpose-built for invoicing rather than full accounting. If you generate a lot of invoices, use recurring billing, or need a clean client portal, easybill is excellent. E-invoicing features are comparable to sevDesk.
What it does well:
- XRechnung and ZUGFeRD generation with profile selection
- Recurring invoice automation
- E-mail delivery with tracking
- Simple, fast interface
Pricing: Free plan (12 documents/year) — genuinely usable for very small freelancers. Paid plans from €9/month (60 documents) or €19/month (unlimited).
Read our full easybill review for detail on format support.
Lexware lexoffice — Best for Freelancers with a Steuerberater
lexoffice (by Lexware) is particularly strong if your tax advisor already uses DATEV/Lexware tools. The integration is seamless, and it handles VAT returns, income/expense tracking, and e-invoicing in one place.
What it does well:
- ZUGFeRD and XRechnung supported
- Deep DATEV integration
- Bank reconciliation
- Suitable for Freiberufler and Gewerbetreibende alike
Pricing: From €7.90/month (invoicing only). Full accounting from €16.90/month.
Read our lexoffice review for more.
Free / Low-Cost Options
If you issue very few invoices and want to minimise costs:
- Invoice Ninja (open-source, self-hostable) — has ZUGFeRD support in the paid hosted version
- Mustangproject — command-line tool, generates valid ZUGFeRD XML, free but not beginner-friendly
- ZUGFeRD online generators — several exist for one-off invoice creation; fine as a stopgap, not for ongoing use
Compare all tools side by side at our software comparison page.
Cost Reality Check
You don't need to spend much. Here's what a freelancer realistically needs:
| Situation | Recommended tool | Estimated monthly cost |
|---|---|---|
| Very few invoices (<10/year), Kleinunternehmer | easybill free plan | €0 |
| Regular freelancer, 10–50 invoices/year | easybill S plan or sevDesk S | €9–€14/month |
| Freelancer with DATEV tax advisor | lexoffice S or sevDesk | €8–€14/month |
| High-volume invoicing (50+/month) | easybill or sevDesk M | €19–€23/month |
The receiving obligation alone — just being able to open and archive ZUGFeRD files — can be handled for free using open-source viewers. But if you're going to set up a tool anyway, paying €10/month for a complete solution is almost always worth it versus managing XML files manually.
GoBD Archiving: The Part People Overlook
Under GoBD rules, you must retain e-invoices in their original machine-readable form for 10 years. Printing the PDF and deleting the XML is not compliant. The structured data (the XML, either standalone or embedded in a ZUGFeRD PDF) must be preserved and auditable.
All the tools mentioned above handle this automatically. If you're doing it manually, you need a dedicated folder structure with version control and no editing after receipt — and you need to document your archiving process.
Step-by-Step Action Plan
If you haven't done anything yet:
- Check your software. Does your current invoicing tool create ZUGFeRD or XRechnung? If not, it's time to switch or add a tool.
- Set up e-invoice receiving. Install a viewer (Mustangproject or similar) or switch to cloud software that imports e-invoices natively.
- Test your setup. Ask a supplier or trusted contact to send you a test ZUGFeRD invoice and confirm you can open, read, and archive it.
- Check your archiving. Ensure your XML files are preserved in their original form and backed up.
If you're already on cloud accounting software:
- Confirm that ZUGFeRD/XRechnung output is enabled (it may need to be turned on in settings).
- Check which ZUGFeRD profile your software uses — EN 16931 is what you want.
- Send a test invoice to yourself or a colleague to verify the format.
If you're a Kleinunternehmer:
- Ensure you can receive structured e-invoices (steps 2–4 above).
- No urgency on sending — PDFs remain valid for you until at least 2028.
- Consider getting onto a compliant platform now so the 2028 transition is seamless.
Key Dates to Put in Your Calendar
- 1 January 2025 — Receiving obligation active. You must be able to receive e-invoices now.
- 1 January 2027 — Sending mandatory if your 2025 revenue exceeded €800,000.
- 1 January 2028 — Sending mandatory for everyone, including you if under €800k.
Bottom Line
The e-invoicing mandate is not optional, even for freelancers. The receiving requirement is already in force. The sending deadline is 2028 for most small operators — but getting compliant software in place now means you're protected, professional, and ready when your clients start requesting structured invoices well ahead of any legal deadline.
Pick a tool, run a test invoice, and you'll be done in an afternoon.