The B2B e-invoicing obligation in Germany: deadlines through 2028 and how dCM implements them

Since 1 January 2025, e-invoicing has been mandatory in Germany for transactions between businesses. Many companies still send their invoices as a PDF by email and assume that this already counts as an electronic invoice. That is a misconception, and it can become expensive. We explain what the obligation actually means, which deadline applies until when, and how the requirements can be met cleanly with the document flow in dCM.

What the e-invoicing obligation has required since 2025

With the German Growth Opportunities Act (Wachstumschancengesetz), the legislator made the electronic invoice mandatory for domestic business-to-business (B2B) transactions. The rollout is staggered so that companies of every size can prepare:

• Since 1 January 2025: every company must be able to receive and process electronic invoices. Anyone who receives an e-invoice can no longer claim not to be set up for it.
• Until 31 December 2026: invoices may still be sent on paper or as a simple PDF, provided the recipient agrees.
• Until 31 December 2027: this transition period additionally applies to issuers whose total turnover in the previous year did not exceed 800,000 euros.
• From 1 January 2028: the e-invoice becomes mandatory for all domestic B2B transactions.

For invoices to public-sector clients (business-to-government, B2G), the XRechnung format has long been the standard anyway. Purely private consumers (B2C) are not affected by the obligation.

Why a PDF is not an e-invoice

The most common misconception: a PDF sent by email is not an e-invoice in legal terms. An e-invoice within the meaning of the law is a structured data set based on the European standard EN 16931 that software can read and process automatically. A PDF is readable for people, but to a machine it is just an image. Two formats have become established in Germany:

• ZUGFeRD 2.x: a hybrid format. What you see is a PDF/A-3, but the structured invoice data is additionally embedded as XML. People see the familiar invoice, systems read the XML.
• XRechnung: pure XML with no visible layout, required above all in the public-sector context.

Both meet the EN 16931 standard and therefore qualify as a valid e-invoice. For the recipient this brings a tangible benefit: the invoice can be taken straight into accounting without retyping, so transposed digits and data-entry errors disappear. Conversely, anyone who keeps sending only a PDF after the deadline risks having the document objected to as improper, which delays payment.

How dCM implements the e-invoice

The e-invoice is built firmly into the document flow of dCM, not bolted on as an add-on module. That means it is created exactly where you are already working.

Formats without extra software

dCM produces both ZUGFeRD 2.x, as a PDF/A-3 with embedded XML, and pure XRechnung in line with EN 16931. You decide per document or per customer which format is issued, with no second program in between.

A seamless document cycle

Quotation, order, order confirmation, delivery note and invoice are created in one system and are linked without gaps. Follow-up documents are generated on demand from their predecessors, including quantity tracking for partial or combined draw-downs. Custom document types and continuous number ranges can be set up freely, for example a dedicated repair order.

GoBD compliance from the start

As soon as a document has been issued or sent, dCM locks it so it can no longer be changed. Corrections are only possible via cancellation or credit note, each with a traceable audit trail. Document numbers are preserved and number ranges stay gapless and collision-free. That is exactly what tax auditors expect. (GoBD are Germany's principles for the proper keeping and storage of books and records in electronic form.)

Onward into accounting

Outgoing and incoming invoices can be handed over to the tax advisor via a DATEV export. Through the cloud export, invoices move automatically into a WebDAV target such as Nextcloud or OneDrive, and payment reconciliation via the bank connection matches incoming payments to the correct documents automatically.

What you should do now

• Check your ability to receive: can you accept and archive incoming ZUGFeRD and XRechnung invoices? That has been mandatory since 2025, regardless of when you have to start sending them yourself.
• Decide on a format: ZUGFeRD is practical for mixed groups of recipients because it is both human-readable and machine-processable. For public-sector clients you need XRechnung.
• Sort out archiving: e-invoices must be stored in a GoBD-compliant and unalterable way. The visible layout alone is not enough; the structured data is what matters.
• Adjust your processes: master data, number ranges and approvals should be in place before the next deadline arrives.

Conclusion

The e-invoice is no longer a distant announcement; it has been applicable law since 2025, with clear deadlines through 2028. Companies that implement it cleanly and early spare themselves the rush shortly before the cut-off date and, along the way, gain a seamless, audit-proof document flow. We would be happy to show you how dCM produces ZUGFeRD and XRechnung and embeds them into your existing processes.

Note: This article provides general information about the e-invoicing obligation in Germany. It does not constitute legal or tax advice.

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