Germany · e-invoicing mandate

Germany's 2027 B2B e-invoicing mandate: what Shopify merchants must do

Last updated 2 September 2026

If you sell B2B into Germany from Shopify, the paper or PDF invoice you send today will not be enough. Germany is phasing in mandatory structured e-invoices (XRechnung / ZUGFeRD), and the big deadline — sending — lands on 1 January 2027. Here's exactly what changes, and what a Shopify store needs to do about it.

What is actually changing

Under Germany's Growth Opportunities Act (Wachstumschancengesetz), a compliant B2B invoice must be a structured electronic invoice that follows the European standard EN 16931. A PDF is not a structured e-invoice — it's just a picture of one. The rules roll out in stages so businesses can prepare.

The rules are in §14 UStG. How the tax authorities read them is set out in the BMF letter of 15 October 2024 (BStBl I p. 1320), as amended by the BMF letter of 15 October 2025, file reference III C 2 - S 7287-a/00019/007/243. That letter rewrites section 14.1 of the German VAT application decree (UStAE), and it is the source for everything on this page that says what Germany requires. Its own scope rule: the principles apply to every supply carried out after 31 December 2024, with the transitional rules running to 31 December 2027.

Date	What becomes mandatory
1 Jan 2025	Every German business must be able to receive EN 16931 e-invoices. Paper/PDF still allowed to send (with the buyer's consent) during the transition.
1 Jan 2027	Businesses with prior-year turnover above €800,000 must send e-invoices for domestic B2B.
1 Jan 2028	All remaining German businesses must send e-invoices for domestic B2B.

Who this hits first: if your German turnover was over €800k last year, your 2027 invoices to business customers must be structured e-invoices. Everyone else follows in 2028 — but buyers increasingly expect them now, and you must already be able to receive them. Receiving has been mandatory since 1 January 2025 and has no transitional relief: section 14.1 (5) sentence 1 UStAE requires every domestic business to put the technical conditions for receiving an e-invoice in place, and sentence 2 says that holds even for small businesses under §19 UStG. The transitional rules to the end of 2027 cover issuing only.

XRechnung vs ZUGFeRD — what counts as compliant

The test is the European standard, not a brand name. Section 14.1 (11) sentence 3 UStAE puts it plainly: using an invoice format that conforms to the EN 16931 series is always permitted. Section 14.1 (12) then names the two German ones and adds, in sentence 3, that the choice is not limited to national formats as long as they conform to EN 16931. Two formats dominate in Germany, and the difference between them is smaller than it looks:

XRechnung — a pure XML invoice. Machine-readable, no visual layout. Common for public-sector and larger buyers.
ZUGFeRD — a hybrid: a normal-looking PDF with the EN 16931 XML embedded inside it. Your buyer sees a familiar PDF; their software reads the structured data. This is the friendliest option for most SMB B2B. Section 14.1 (14) sentence 4 UStAE is specific about the version: ZUGFeRD from 2.0.1, excluding the MINIMUM and BASIC-WL profiles, which do not carry every mandatory VAT field.

Peppol BIS Billing 3.0 UBL is not named in the letter, and it does not need to be. It conforms to EN 16931, which is the condition section 14.1 (11) and (12) actually state, so it discharges §14 UStG on the same footing as XRechnung.

How the invoice reaches your buyer

A common misconception: that you must join the Peppol network. You don't — Germany mandates the format, not the channel, and the BMF letter says so in as many words. Section 14.1 (4) sentence 6 UStAE lists the ways an e-invoice may be transmitted: by email, by download from an internet portal, by EDI, by making the data available through an electronic interface, or through shared access to a central storage location. Sentence 7 adds that which permitted format and which permitted transmission route the parties settle on is a matter of civil law between them. No network is prescribed anywhere in the letter, and Peppol is not mentioned in it at all. A ZUGFeRD invoice can be delivered by email (by agreement with the buyer), which is how most German SMB e-invoicing already works. Peppol is a great option when your buyer is on it, but it's not required.

The part everyone underestimates: VAT correctness

An EN 16931 invoice is validated. If the numbers don't add up to the cent — net, VAT and gross — it can be rejected. Pulling clean figures out of Shopify is harder than it looks:

Whether your prices include or exclude tax changes how net and VAT are derived.
Rounding differences can leave net + VAT off from gross by a cent — enough to fail validation.
Selling to a VAT-registered business in another EU country usually means reverse charge (0% VAT, with the correct legal note) — and the buyer's VAT number should be checked against VIES.

Get any of these wrong and you're not compliant, even if the format is perfect.

Germany is the format-only model: an obligation about what the invoice is, with no central platform. The EU e-invoicing mandate table shows how the other twenty-six member states answered the same question, and when each one starts.

Because the obligation is about the format, a lot of apps can satisfy it, and their listings do not always say which country they reach. If you are shortlisting, we keep sourced comparisons with Sufio and ElkSend, the two most likely to come up against us here.

Frequently asked questions

When does Germany's B2B e-invoicing mandate start?

Receiving has been mandatory since 1 January 2025, with no transitional relief (section 14.1 (5) sentence 1 UStAE, as set by the BMF letter of 15 October 2025). Sending becomes mandatory from 1 January 2027 for businesses with prior-year turnover above €800,000, and from 1 January 2028 for everyone else, under the transitional rules in §27 (38) UStG.

Which formats are accepted?

Any format meeting EN 16931. Section 14.1 (11) sentence 3 UStAE says a conforming format is always permitted, and (12) sentence 3 says the choice is not limited to national formats. In Germany that is typically XRechnung (pure XML) or ZUGFeRD from version 2.0.1, excluding the MINIMUM and BASIC-WL profiles.

Do I have to use the Peppol network?

No. Germany mandates the format, not the channel. Section 14.1 (4) sentence 6 UStAE lists email, portal download, EDI, an electronic interface and shared access to a central storage location as ways to transmit an e-invoice, and sentence 7 leaves the choice to the parties. Peppol is not named in the BMF letter at all, so it is optional.

Does this apply to B2C orders?

No — only domestic B2B between businesses established in Germany. Consumer invoices are out of scope.

What if my invoice isn't compliant?

It can be rejected and, for VAT purposes, treated as not properly issued — which can affect the buyer's input-VAT deduction and create rework for you.

This guide is general information for Shopify merchants, not legal or tax advice. Rules and thresholds can change and edge cases exist — confirm your obligations with a qualified tax adviser. Source for the requirements stated here: BMF letter of 15 October 2024 (BStBl I p. 1320), as amended by the BMF letter of 15 October 2025 (file reference III C 2 - S 7287-a/00019/007/243, DOK COO.7005.100.4.13163130), which restates section 14.1 UStAE. Dates and thresholds for the transitional rules are from §27 (38) UStG. Checked on 2 September 2026.

E-invoices from your Shopify B2B orders

Zeppol turns every B2B order into an EN 16931 document, checks it against the EU and the German rules, and sends it over Peppol or by email. Join the list and I'll be in touch before the deadline.