Germany E-Invoicing News & Updates 2026

Germany's e-invoicing mandate is now in its second year. Since January 2025, the receiving requirement has been live — all German businesses must be able to accept structured electronic invoices. The next milestone: from January 2027, businesses with revenue over €800,000 must also send e-invoices. From January 2028, this applies to all German VAT-registered businesses.

Here's what's new in 2026 and what you need to track.

April 2026 — BMF Confirms 2027/2028 Sending Deadlines

What happened: The Bundesministerium der Finanzen (BMF) confirmed in its Q1 2026 communications that the sending deadlines established in the Wachstumschancengesetz remain unchanged:

1 January 2027: Businesses with annual turnover above €800,000 must send structured e-invoices for B2B transactions
1 January 2028: All German VAT-registered businesses must send structured e-invoices for B2B transactions

What this means for you: If your business has revenue above €800,000, you now have less than 9 months to be ready to send. If you haven't started your e-invoicing implementation, prioritise it now. See our implementation guide for a step-by-step process.

March 2026 — XRechnung 3.1 Specification Draft Published

What happened: KoSIT published a draft of XRechnung version 3.1 for public comment. The current production version is XRechnung 3.0 (mandatory since February 2024).

Key changes proposed in XRechnung 3.1:

Clarifications on Leitweg-ID handling for multi-level public sector entities
Updated validation rules for cross-border invoices processed through the B2B channel
Alignment updates with EN 16931:2017+A1:2019 (the European standard)
Improved guidance for self-billing (Gutschrift) scenarios

Timeline: The 3.1 specification is expected to be finalised in Q3 2026 with a transition period before it becomes mandatory. Most software providers will update automatically; if you generate XRechnung from custom code or an ERP integration, monitor the KoSIT release notes.

February 2026 — ZUGFeRD 2.3.2 Released

What happened: The FeRD (Forum Elektronische Rechnung Deutschland) released ZUGFeRD 2.3.2, a maintenance update to the current ZUGFeRD standard.

What changed in 2.3.2:

Bug fixes in the XMP metadata specification embedded in the PDF
Updated test file samples for the EN 16931 profile
Minor clarifications to the BOM (Business Object Model) documentation
No changes to the XML schema structure

Impact: For most businesses and software users, ZUGFeRD 2.3.2 is a non-breaking update. Your existing ZUGFeRD 2.3 documents remain valid. However, if you issue ZUGFeRD documents programmatically, check whether your library has been updated to version 2.3.2.

Compliance note: For the B2B e-invoicing mandate, only the EN 16931 and XRechnung ZUGFeRD profiles are compliant. The Minimum, Basic WL, and Basic profiles do NOT meet the mandate requirements — they lack the structured data required by EN 16931.

January 2026 — 12-Month Review: Receiving Mandate Compliance

What the market found: Following the first full year of the receiving mandate (B2B receiving mandatory since January 2025), industry surveys and Steuerberater associations reported:

~75% of large businesses (500+ employees) were fully compliant with receiving by December 2025
~50% of SMBs (10-499 employees) had implemented structured e-invoice receiving
~25% of micro-businesses (<10 employees) were still primarily using PDF invoices and manual processing
Most common gap: Businesses could receive the PDF layer of ZUGFeRD but were not processing the XML structured data — this is technically non-compliant with the mandate

Key insight: Receiving an e-invoice means being able to process the structured XML data, not just view the PDF. If your current process involves printing the PDF or manually entering data, you are not compliant with the January 2025 requirement.

Q4 2025 — OZG-RE Replaces ZRE for Federal Invoicing

What happened: The federal government completed the transition from the older ZRE (Zentraler Rechnungseingang) to the modernised OZG-RE portal. The OZG-RE offers:

Improved API access for high-volume submitters
Better Peppol routing for inbound invoices
Enhanced status tracking and error reporting
Streamlined Leitweg-ID management for federal entities

Action required for B2G suppliers: If you were using the ZRE, migrate to OZG-RE. ZRE remains operational but OZG-RE is the recommended path. Update your submission endpoint if you use direct API integration.

2025 Year in Review: Key Milestones

A summary of what happened in 2025 that is now in effect:

January 2025 — Receiving mandate live. All German B2B businesses required to accept structured e-invoices in XRechnung, ZUGFeRD 2.x (EN 16931 profile), or Peppol BIS 3.0 format.

October 2025 — BMF clarification on transition period. The BMF clarified that invoices sent on paper or as non-structured PDFs between January 2025 and January 2027 remain valid (with recipient consent), but the recipient must be technically capable of receiving structured invoices even if they accept non-structured ones in this period.

Throughout 2025 — Software market matured. Major German invoicing tools (sevDesk, easybill, Lexware, FastBill, Billomat, Sage) all achieved full XRechnung 3.0 and ZUGFeRD 2.3 compliance. DATEV updated its full product range for receiving and sending.

Upcoming Milestones

Date	Event
1 January 2027	Sending mandate for businesses with >€800k revenue
1 January 2028	Sending mandate for all German VAT-registered businesses
2026 Q3	XRechnung 3.1 expected to be finalised
2028	EU ViDA (VAT in the Digital Age) expected implementation — impacts cross-border digital reporting

What to Do Now (April 2026)

If your revenue is above €800,000:

If you haven't started sending e-invoices yet, start the project now. Implementation typically takes 2-6 months depending on your ERP and process complexity.
Verify your software can produce XRechnung 3.0 and/or ZUGFeRD 2.x with EN 16931 profile
Run test invoices through the KoSIT validator

If your revenue is below €800,000:

Focus on receiving first — you should already be compliant with receiving
Plan your sending implementation for mid-2027 at the latest
Choose software now; most implementation work is in data mapping and process setup, not last-minute software selection

Resources

Last updated: 18 April 2026. We update this article as new regulatory guidance and specification updates are published.