On 1 January 2025, Germany's Wachstumschancengesetz introduced a mandatory e-invoicing requirement for all domestic B2B transactions. If your business invoices German companies — or receives invoices from them — this affects you.
What the law actually requires
The regulation mandates that all invoices between VAT-registered businesses established in Germany must be issued as structured electronic documents conforming to the EN16931 European standard. A PDF sent by email no longer qualifies as an electronic invoice under this definition.
The two accepted formats are:
- XRechnung 3.0 — pure XML (UBL or CII), required for invoices to public-sector buyers
- ZUGFeRD 2.x — a PDF/A-3 with embedded XML, widely used in B2B
Who is affected and when
The rollout is phased to give businesses time to adapt:
- January 2025 — All businesses must be able to receive structured e-invoices
- January 2027 — Businesses with annual revenue above €800,000 must issue structured e-invoices
- January 2028 — All remaining businesses must issue structured e-invoices
Cross-border transactions (outside Germany) are not yet in scope, but EU-wide rules are expected to follow by 2030 under the ViDA initiative.
What counts as a structured invoice?
The invoice must contain machine-readable data that maps to the EN16931 semantic data model. This means fields like buyer and seller tax IDs, line-item descriptions, VAT breakdown, and payment terms must all appear as structured XML elements — not just as text in a PDF.
A PDF with a QR code, or a PDF generated from a Word template, does not qualify.
Practical steps for businesses
- Check whether your accounting software can export XRechnung or ZUGFeRD — most major German ERP systems (DATEV, SAP, Lexoffice) already support one or both
- If you use a custom billing system or ERP, integrate a validation API to ensure every invoice you issue is compliant before it leaves your system
- Set up an inbox that can parse incoming structured invoices — many DATEV-compatible accountants can handle this for SMEs
How xingen helps
Small businesses can use the xingen web app to validate and export invoices in the correct format without touching any code. Development teams can integrate the xingen REST API to embed EN16931 validation directly into their invoicing pipeline — catching errors before they reach the customer.