E-invoicing obligation by 2025

The comprehensive guide: Deadlines, formats & implementation in SAP

Since January 1, 2025 E-invoicing is mandatory in Germany. All companies must be able to receive electronic invoices – and from 2027/2028 onwards, also send them. This guide explains everything you need to know: deadlines, formats, exceptions, and implementation in SAP.

What is the e-invoicing obligation?

The e-invoicing obligation requires companies in Germany to create, send, and receive electronic invoices in a structured data format. This is based on the... Growth Opportunities Act, which was adopted by the Federal Council on March 22, 2024 and fundamentally changed Section 14 of the Value Added Tax Act (UStG).

An e-invoice within the meaning of the law is not Simply send an invoice in PDF format via email. This is an invoice in a structured electronic format that allows for automatic processing. The invoice must comply with the European standard. EN 16931 be compatible or interoperable with it.

For companies using SAP as their ERP system, this means that e-invoicing processes must be directly integrated into SAP – for both incoming and outgoing invoices. Solutions such as GOpus® eInvoice This seamless integration is precisely what enables it.

Who is affected by the e-invoicing obligation?

The obligation to issue e-invoices generally applies all companies in Germany, who operate in the B2B (business-to-business) sector:

  • All domestic B2B sales – regardless of company size or industry
  • Corporations (GmbH, AG) as well as partnerships and sole proprietor
  • Corporations using SAP systems just like medium-sized companies
Exceptions to the e-invoicing requirement:
  • Small value invoices up to €250 (according to §33 UStDV)
  • Travel tickets (according to §34 UStDV)
  • Tax-exempt services according to §4 Nos. 8 to 29 UStG
  • B2C invoices – invoices to private individuals are not affected

Important: The obligation to Reception The requirement for e-invoices has been in effect for all companies since January 1, 2025 – without exception and without a transition period.

Timetable and transition periods

The legislator has provided for a phased timetable with transition periods:

From 1 January 2025
Obligation to receive
All businesses must be able to receive e-invoices.
Until December 31, 2026
transition period
Paper and PDF documents are still allowed for sending.
From 1 January 2027
Shipping obligation >€800k
Companies with a turnover of over €800,000 in the previous year.
From 1 January 2028
Shipping obligation for all
All B2B companies, without exception.

Which e-invoice formats are permitted?

Not every electronic document qualifies as an e-invoice. Legislation requires a structured format according to the European standard EN 16931:

XRechnung

German standard, pure XML format according to EN 16931. Mandatory for B2G since 2020, now also a B2B standard. Ideal for fully automated processing.

ZUGFeRD 2.x

Hybrid format: PDF + embedded XML. Profiles COMFORT, EXTENDED and XRECHNUNG are EN-16931 compliant. Profile MINIMUM is sufficient. not out of.

Factur-X

German-French equivalent to ZUGFeRD, technically identical. Particularly relevant for cross-border invoices between Germany and France.

Peppol BIS Billing 3.0

European network for e-documents. Based on EN 16931, ideal for international invoice exchange and connection to government agencies.

This does NOT count as an e-invoice: PDF invoices via email • Scanned paper invoices • Word or Excel files • Image files (JPG, PNG) • ZUGFeRD profile MINIMUM

Checklist: How to prepare your company

The switch to e-invoicing affects not only IT, but also processes, organization and compliance:

  1. Ensure reception capability – Can you receive and process XRechnung and ZUGFeRD files? Mandatory since January 1, 2025.
  2. Inventory of invoicing processes How are invoices created, sent, received, and archived? Where are there breaks in the process?
  3. Check ERP system Does your SAP system support these formats? Is an add-on like this one available? GOpus® eInvoice necessary?
  4. Set format – XRechnung for machine processing or ZUGFeRD for visual + machine representation?
  5. Inform business partners – Coordinate future formats and transmission methods with customers and suppliers.
  6. Adjust archiving – Ensure GoBD-compliant, audit-proof archiving (10-year retention requirement).
  7. Set up validation - With a E-Invoice Validator Check for compliance with standards.
  8. Conduct test phase – Test the entire process with selected business partners.
  9. Employees are trained – Familiarize financial accounting, purchasing and IT departments with new processes.
  10. Keeping deadlines in mind – Plan sufficient lead time for the changeover.

Implementing mandatory e-invoicing in SAP

For companies using SAP ERP or SAP S/4HANA, direct integration into existing SAP processes is the most efficient approach. A standalone solution outside of SAP creates media breaks and additional manual effort.

GOpus® eInvoice – SAP certified

Outgoing invoice: XRechnung, ZUGFeRD, Factur-X & Peppol directly from SAP (SD, FI, MM, RE/FX)
Invoice received: Automatic processing with assignment to orders and suppliers
All formats: EN-16931 compliant plus international formats
Validation: Integrated validator checks each invoice before sending.
Archiving: GoBD-compliant storage of structured invoice data
Implementation: 2 to 6 weeks, without modifying the SAP standard

Success story: Westfalen AG

The Westfalen AG GOpus® eInvoice has integrated the entire e-invoicing process into SAP – from invoice receipt and automatic processing to sending in all relevant formats. The result: full compliance with e-invoicing regulations and a significant reduction in manual effort in accounting.

Frequently asked questions about the obligation to issue e-invoices

What is the e-invoicing obligation and who does it affect?
With the Growth Opportunities Act, electronic invoicing for B2B transactions has been gradually becoming mandatory in Germany since January 1, 2025. Since 2025, all companies must be able to receive e-invoices. Transitional periods apply to sending e-invoices until the end of 2026, from 2027 for companies with a turnover exceeding €800,000, and from 2028 for all companies.
What happens if I fail to comply with the e-invoicing obligation?
Input tax deduction can be jeopardized if incoming invoices are not processed correctly. This can lead to objections during tax audits. From 2027/2028, invoices without the correct e-invoice format may be considered non-compliant. In the worst case, this can result in estimated tax assessments and fines.
What transitional periods apply?
Since January 1, 2025: Mandatory receipt of invoices for everyone. Until the end of 2026: Paper and PDF invoices may still be sent. From 2027: Mandatory sending for companies with a turnover exceeding €800,000 in the previous year. From 2028: Mandatory sending for all B2B companies.
How do I implement the e-invoicing requirement in SAP?
With GOpus® eInvoice The mandatory e-invoicing requirement can be implemented directly in SAP ERP and S/4HANA. The solution integrates creation, sending, and receiving into the standard SAP process. XRechnung, ZUGFeRD, Factur-X, and Peppol are supported. Implementation: 2 to 6 weeks.
What is the difference between ZUGFeRD and XRechnung?
XRechnung is a pure XML format – machine-readable, but without visual representation. ZUGFeRD 2.x It combines a PDF file with embedded XML. Both are based on EN 16931 and are equally permissible. More information can be found in the [link/section]. eInvoicing A-Z Glossary.
How long does the introduction take?
GOpus® eInvoice implementation takes 2 to 6 weeks – depending on the complexity of your SAP landscape. A proof of concept can be set up in just a few days.
Do I need to archive e-invoices?
Yes. E-invoices are subject to the GoBD and must be archived in their original format in an audit-proof manner – 10-year retention period. A printout or conversion is not sufficient.
Does the e-invoicing requirement also apply internationally?
The German obligation initially applies to domestic B2B sales. However, more and more countries are introducing their own regulations. Overview: E-invoicing regulations by country. GOpus® eInvoice also supports international formats.
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