Germany E-Invoicing for Freelancers and Kleinunternehmer: What You Actually Need to Do
The German e-invoicing mandate explained for freelancers, solopreneurs, and Kleinunternehmer. What the 2025 receiving mandate means for you, who the 2027 and 2028 sending mandates apply to, and which free or affordable tools cover your needs.
Germany E-Invoicing for Freelancers and Kleinunternehmer: What You Actually Need to Do
If you are a freelancer (Freiberufler), self-employed person (Selbstständiger), or a Kleinunternehmer in Germany, you have probably seen headlines about Germany's e-invoicing mandate and wondered: does this apply to me, and if so, what do I need to do?
This guide answers those questions plainly, without unnecessary jargon.
The Short Answer by Business Type
| Your Situation | 2025 Mandate | 2027 Mandate | 2028 Mandate |
|---|---|---|---|
| Freelancer billing B2B (>€800k revenue) | Must receive | Must send | Must send |
| Freelancer billing B2B (<€800k revenue) | Must receive | Not required yet | Must send |
| Kleinunternehmer (§19 UStG, no VAT) | Not required | Not required | Not required |
| Freelancer billing consumers only (B2C) | Not required | Not required | Not required |
| Freelancer billing public authorities | Must send XRechnung | Already applies | Already applies |
Understanding the Three Mandate Dates
1 January 2025: Receiving Mandate (Already Active)
Since 1 January 2025, every German B2B business must be able to receive structured e-invoices — meaning XRechnung XML or ZUGFeRD PDF — without the invoice being rejected.
What "able to receive" means for a freelancer:
- You do not have to accept electronic invoices you do not want
- But you cannot legally refuse to accept an XRechnung from a supplier just because you prefer PDF
- In practice: if a supplier sends you an XRechnung XML, you need to be able to open and process it
What you actually need to do: Download a free XRechnung viewer (see below) or use software that reads ZUGFeRD PDF automatically. Most modern accounting tools (sevDesk, FastBill, easybill, Lexware) handle this already.
1 January 2027: Sending Mandate (Large Businesses)
Businesses with 2025 annual revenue above €800,000 must send XRechnung or ZUGFeRD (EN 16931 profile) for all domestic B2B invoices from January 2027.
Does this apply to you? If your revenue is below €800,000, the 2027 mandate does not apply to you — but your customers above that threshold will start sending you structured invoices (which you must be able to receive, per the 2025 mandate).
1 January 2028: Universal Sending Mandate
From January 2028, all German B2B businesses must send structured e-invoices — regardless of revenue. This is when even freelancers billing <€800k must send XRechnung or ZUGFeRD.
What this means: By January 2028, you need invoicing software that generates XRechnung 3.0 or ZUGFeRD 2.3 EN 16931 profile. You have two years from today to prepare.
The Kleinunternehmer Exception
If you operate under the Kleinunternehmerregelung (§19 UStG) — you are VAT-exempt because your revenue is below the threshold (currently €22,000/year) — the e-invoicing mandate does not apply to you as a sender.
Why: The mandate applies to VAT-registered businesses issuing VAT invoices. As a Kleinunternehmer, your invoices do not carry VAT, so you are outside the scope.
However:
- If your B2B customers send you structured e-invoices, you must be able to receive them (2025 mandate)
- If you ever exceed the Kleinunternehmer threshold and register for VAT, the mandate will apply to you
The B2C Exception
If you invoice only consumers (private individuals, not businesses), the mandate does not apply. German e-invoicing mandates cover only B2B transactions (business-to-business).
If you do a mix of B2B and B2C (common for consultants, therapists, coaches), the mandate applies only to your B2B invoices.
How to Receive XRechnung Today (Free Solutions)
To open and read XRechnung XML files from suppliers, you have several free options:
Option 1: Free Online Viewer (BMF/XEINKAUF)
The German government provides a free XRechnung visualiser at the KOSIT viewer portal. Upload an XML file and see it rendered as a human-readable invoice.
Option 2: Your Accounting Software
Most German accounting tools already handle XRechnung and ZUGFeRD automatically:
- sevDesk: Reads XRechnung in the inbox
- easybill: Handles both formats natively
- FastBill: Opens XRechnung from the business inbox
- Lexoffice: ZUGFeRD automatic extraction
Option 3: Free XRechnung Viewer Apps
Several Windows/Mac desktop apps render XRechnung XML as PDFs for free. Search for "XRechnung Viewer" in the Windows Store — there are several well-rated free options.
How to Send XRechnung from 2027/2028
When the time comes to send structured e-invoices, you need accounting software with XRechnung or ZUGFeRD support. For freelancers, affordable options include:
| Tool | Price | XRechnung | ZUGFeRD | Notes |
|---|---|---|---|---|
| easybill | Free tier available | ✅ 3.0 | ✅ 2.3 | Best for low-volume freelancers |
| sevDesk | From €8.90/mo | ✅ 3.0 | ✅ 2.3 | Great mobile app |
| FastBill | From €9.99/mo | ✅ 3.0 | ⚠️ 2.1 | Banking integration strength |
| Billomat | From €9/mo | ✅ 3.0 | ⚠️ 2.1 | Developer API |
| Lexoffice | From €5.99/mo | ✅ 3.0 | ✅ 2.3 | Full accounting suite |
If you are currently using Microsoft Word or a PDF tool to create invoices, you will need to switch to one of these before January 2028.
The B2G Situation (Invoicing Government Clients)
If you freelance for any German public authority — federal government, state agencies, municipalities, public-sector clients — you are already required to use XRechnung for those invoices. This has been mandatory since 2020 for federal contracts and 2022 for all public procurement.
For freelancers with public sector clients: If your accounting software does not currently generate XRechnung, you are technically non-compliant for those invoices right now — not in 2027. This is the most urgent e-invoicing requirement for freelancers.
Practical Action Plan
Today (freelancers billing B2B, any revenue):
- Make sure your accounting software can receive XRechnung / ZUGFeRD (most modern tools do)
- If you invoice public authorities: activate XRechnung sending immediately
- If you use Word, Google Docs, or PDF for invoices: start evaluating accounting software
By January 2027 (if revenue >€800k):
- Activate XRechnung or ZUGFeRD sending in your accounting software
- Validate a sample invoice with the KoSIT validator
- Inform your major B2B customers of the format switch
By January 2028 (all remaining freelancers billing B2B):
- Same as above — but you have until 2028 to complete this
Summary
The German mandate is not as complex as the headlines suggest. For freelancers:
- 2025: Make sure you can open XRechnung/ZUGFeRD from suppliers ← most already done
- 2027: Only affects you if revenue > €800k
- 2028: Affects everyone — but you have two full years from today
- Kleinunternehmer: Largely exempt from sending; just need to be able to receive
If you are already using proper invoicing software (sevDesk, easybill, FastBill, Lexoffice), you are 90% of the way there. The remaining 10% is activating the e-invoice format and validating the output.