E-Invoicing for German Freelancers (Freiberufler) in 2026: Exactly What You Need to Do

Germany's e-invoicing mandate is structured in phases, and most freelancers are not in the first wave. But "not in the first wave" does not mean "not affected yet." There are obligations that already apply to German freelancers as of 2025 — and understanding the timeline can save you from scrambling at the last minute.

German tax law defines Freiberufler as members of the liberal professions: doctors, dentists, lawyers (Rechtsanwälte), architects, engineers, tax advisors (Steuerberater), journalists, artists, IT consultants (as a recognised category), and similar.

Freiberufler are subject to income tax (Einkommensteuer) but exempt from Gewerbesteuer (trade tax). For e-invoicing purposes, they are treated identically to regular businesses — their Freiberufler status does not exempt them from the mandate.

A Kleinunternehmer is a business (including a Freiberufler) whose previous-year turnover was below €25,000 (from 2025; previously €22,000) and whose current-year turnover is expected to remain below €100,000.

Kleinunternehmer do not charge VAT on invoices and do not file quarterly VAT returns (Umsatzsteuervoranmeldung). For e-invoicing, this creates a special situation:

• Receiving: From 1 January 2025, ALL businesses — including Kleinunternehmer — must be capable of receiving structured e-invoices. You do not have to use a specific software, but you cannot refuse a structured e-invoice from a supplier.
• Sending: Kleinunternehmer invoices do not contain VAT. Under the current German guidance, the sending obligation (2027/2028) technically applies to invoices "between domestic taxable persons" where VAT applies. The BMF has clarified that Kleinunternehmer who issue §19 invoices (no VAT) may be exempt from the sending mandate — but this remains a grey area. Most tax advisors recommend implementing ZUGFeRD anyway to future-proof workflows.

Most Freiberufler with turnover above the Kleinunternehmer threshold charge 19% or 7% VAT and file regular Umsatzsteuererklärungen. For these freelancers:

• From 1 January 2025: Must be able to receive structured e-invoices
• From 1 January 2027: Must send structured e-invoices if previous-year turnover exceeded €800,000
• From 1 January 2028: Must send structured e-invoices regardless of turnover

For a freelancer who receives 5–20 supplier invoices per month, the receiving obligation is essentially already met by any modern accounting software or even Gmail + a PDF viewer.

The 2027 sending mandate applies to businesses with previous-year turnover exceeding €800,000. Most German freelancers — particularly individual Freiberufler — will not cross this threshold. For them, the 2028 mandate is the relevant date.

However, this does not mean waiting until January 2028 to implement. Practical reasons to implement earlier: 1. Your clients (grandes entreprises, ETI) will begin requesting structured invoices from their German suppliers as they update their procurement systems in 2026–2027 2. ZUGFeRD invoices reduce payment processing time for large clients — they are processed automatically without manual data entry 3. Software implementation takes time — waiting until Q4 2027 means competing for implementation resources alongside thousands of other businesses

If you only invoice private businesses, ZUGFeRD is simpler, works via email, and meets all B2B requirements.

BMF official e-invoicing FAQ and guidance: bundesfinanzministerium.de

Steuerberaterkammer guidance for Freiberufler: bstbk.de