Mandatory E-Invoicing 2025–2028: The Roadmap for SMEs

In the German B2B sector, the e-invoice is no longer a distant prospect but a legal requirement. The Growth Opportunities Act (Wachstumschancengesetz) has established a binding roadmap. This article summarizes the key deadlines and shows what SMEs should pay attention to — but it does not replace professional tax advice.

What is an e-invoice — and what is not?

An e-invoice within the meaning of the law is an invoice in a structured electronic format that can be processed automatically. Important: a simple PDF does not qualify as an e-invoice — even when it is sent by email. It is merely a digital image of a paper invoice.

The formats permitted in Germany are, in particular:

• XRechnung — a purely structured XML format, well established in public-sector procurement.
• ZUGFeRD (from version 2.x, EN 16931 profile) — a hybrid format combining a PDF with embedded XML, which is both human-readable and machine-processable.

The roadmap at a glance

Effective date	Requirement
1 January 2025	All domestic B2B companies must be able to receive e-invoices
1 January 2027	Obligation to issue for companies with prior-year revenue above €800,000
1 January 2028	Obligation to issue for all domestic B2B companies

Until the respective deadline, paper or PDF invoices may still be sent on a transitional basis with the recipient’s consent. However, the ability to receive has already been mandatory for everyone — including small companies — since the start of 2025.

What this means for SMEs in practice

1. Ensure you can receive (immediately): You must be able to accept and process structured e-invoices. A mailbox alone is not enough — the invoice has to flow into your system.
2. Prepare to issue: Depending on revenue, the obligation applies from 2027 or 2028. Those who switch early avoid last-minute stress.
3. Mind the archiving rules: E-invoices must be retained in their original format in a GoBD-compliant (German principles for the proper keeping and retention of digital records) and unalterable manner.

What to look for in your software

A suitable accounting or ERP solution should:

• be able to both receive and issue XRechnung and ZUGFeRD,
• archive e-invoices in an audit-proof manner (see also our article on GoBD-compliant accounting),
• and integrate into your existing invoicing and bookkeeping workflow.

The accounting module in VertooERP supports XRechnung and ZUGFeRD natively and stores documents in a GoBD-compliant, unalterable manner. Thanks to self-hosting, all invoice data remains within your area of responsibility.

Conclusion

The obligation to receive already applies — the obligation to issue arrives in 2027 or 2028, depending on revenue. SMEs should not wait until the final deadline, but check early on whether their software can receive, issue, and archive e-invoices in an audit-proof way. For a binding assessment of your specific situation, speak with your tax advisor.