E-invoicing in Germany: XRechnung, ZUGFeRD and the 2025–2028 mandate
Germany is moving domestic B2B invoices to structured e-invoices in three steps. Since 1 January 2025 every business must be able to receive them. From 2027 a business with more than €800,000 turnover in the previous year must issue them, and from 2028 every business in scope must. The formats that qualify are XRechnung, ZUGFeRD from version 2.0.1, and other formats that follow the European standard EN 16931. A plain PDF is not an e-invoice under these rules.
Where Guliel stands. Guliel is accounting and finance-operations software that runs invoicing, expenses, purchasing, payroll, reporting and a double-entry general ledger on one engine. For a business based in Germany it issues VAT invoices and credit notes as PDF in the EU/EEA VAT format (live). It does not produce XRechnung, ZUGFeRD or any other structured e-invoice file, and it does not send invoices over Peppol. Structured e-invoice output is planned, with no date yet. Guliel's own Peppol access point is built and awaiting OpenPeppol certification, and it is not connected to the app. If you must issue e-invoices now, use a tool that produces the structured file.
The mandate in short
The rules come from the Growth Opportunities Act (Wachstumschancengesetz), which rewrote §14 of the German VAT Act (UStG). The Federal Ministry of Finance (BMF) sets out the detail in administrative letters and an FAQ.
- E-invoice. An invoice issued, sent and received in a structured format that follows EN 16931 and can be processed automatically. A PDF or a scan is an "other invoice" (sonstige Rechnung), even when it arrives by email.
- Scope. Domestic supplies between businesses established in Germany. Invoices to consumers are out of scope.
- Exceptions. Invoices up to €250 and travel tickets. Small businesses under §19 UStG (Kleinunternehmer) do not have to issue e-invoices, but every business must be able to receive them.
- Channel. Not prescribed for B2B. Email, a portal, an API or the Peppol network all work.
Timeline 2025–2028
| From | Receiving | Issuing domestic B2B invoices |
|---|---|---|
| 1 January 2025 | Every business must be able to receive e-invoices. An email inbox is enough. | Paper is still allowed. A PDF needs the recipient's consent. |
| 1 January 2027 | Unchanged | E-invoices required if total turnover in 2026 was above €800,000. At or below it, paper and PDF stay allowed through 2027. |
| 1 January 2028 | Unchanged | E-invoices required for every in-scope invoice. |
The public sector runs on its own track. Invoices to federal authorities have had to be e-invoices since 27 November 2020, usually XRechnung, sent through the ZRE or OZG-RE portals or over Peppol. The federal states set their own rules.
Legal summary based on the BMF letters on mandatory e-invoicing (Einführung der obligatorischen elektronischen Rechnung) and the BMF FAQ. This is not tax advice: check current BMF publications or ask your Steuerberater before you rely on a cut-off.
XRechnung vs ZUGFeRD
| XRechnung | ZUGFeRD | |
|---|---|---|
| What it is | XML only: the German profile (CIUS) of EN 16931 | A PDF/A-3 with the invoice data embedded as XML |
| Syntax | UBL or UN/CEFACT CII | UN/CEFACT CII |
| Readable by people | Only with a viewer | Yes, through the PDF layer |
| Meets the B2B mandate | Yes | Version 2.0.1 and later, except the MINIMUM and BASIC WL profiles |
| Typical use | Public-sector invoices, and B2B when the buyer asks for it | B2B, when the buyer wants a PDF as well |
Factur-X is the French name for the same hybrid format. In ZUGFeRD the XML is what counts legally; the PDF is a readable copy. Keep every e-invoice in its original format. Since the 2025 change to the retention rules, invoices are kept for eight years and books and annual financial statements for ten.
What Guliel does for a business in Germany today
All of the following is live.
- VAT invoices and credit notes as PDF. Your name, address and VAT ID (USt-IdNr., checked as DE plus nine digits), the customer's name, address and VAT ID, a sequential number allocated at issue, issue and due dates, on invoices the supply date (the document's service period when you set one, otherwise the issue date), line items, VAT and totals, and IBAN and BIC when you attach a bank account. In English, in euros or another currency with the exchange rate stored. More on invoicing.
- VAT at 19% when your organisation is VAT-registered, 0% when it is not. Record a payment against an invoice and Guliel can issue the receipt.
- A double-entry ledger. Issued invoices, approved expenses and payroll post to a double-entry general ledger on a fixed chart of accounts, with manual journal entries that must balance, a trial balance, balance sheet, general ledger report, income statement, cash flow, a books lock date a manager sets, and a CSV export. See accounting.
- Expenses. OCR scans of receipts and bills, and capture from Gmail, Outlook, IMAP or POP3 inboxes. AI assigns a category from your own list; nothing reaches the ledger until a person approves it. Expenses export as CSV, with the source files as a ZIP.
- Purchasing. Purchase orders, supplier records and email invitations to suppliers. A supplier's invoice links to the order it bills.
- Reports. 49 report definitions, including a tax report that sums the VAT on your invoices by rate per month, quarter or year, AR aging, expenses by vendor and income by period, downloadable as PDF.
- Automations and AI. 14 triggers, such as a new invoice, a payment or an overdue invoice; actions are any API operation or an outbound webhook. Any MCP client (Claude, ChatGPT, Copilot) connects through OAuth 2.1 and acts within your role and scopes, as does the built-in AI companion.
- DACH under one login. Austria uses the same EU/EEA VAT format and Switzerland the Swiss VAT format: one organisation per entity, 39 countries in 10 format families.
What Guliel does not do in Germany yet
- Structured e-invoices. No XRechnung, ZUGFeRD, Factur-X or Peppol BIS Billing files, and no sending over Peppol. Structured output is planned; the access point is built and awaiting certification.
- Reading e-invoices you receive. Inbox capture and upload read PDFs and images with OCR. A ZUGFeRD invoice is captured from its PDF layer, not its XML. XRechnung XML files are not accepted.
- Special VAT cases. One rate applies per invoice, and the invoice form does not offer the 7% reduced rate. Guliel does not apply reverse charge: a VAT-registered organisation's invoices carry 19% whoever the customer is. The §19 UStG small-business note goes in the invoice notes.
- German bookkeeping specifics. The chart of accounts is fixed and is not SKR03 or SKR04; custom accounts are planned. There is no DATEV export; the ledger exports as CSV. Guliel has no GoBD audit or attestation.
- Returns and payroll. Guliel does not file the VAT advance return (Umsatzsteuer-Voranmeldung) through ELSTER; VAT return preparation is planned. German payroll runs on the generic profile, without wage tax or social-insurance contributions.
- German-language documents. Invoices print in English. German law allows invoices in another language, though the tax office can ask for a translation.
Using Guliel in Germany now
- Connect. Run Guliel beside the tool you use today: capture and approve expenses, run purchase orders, and export the ledger as CSV for your Steuerberater (live).
- Invoice where a PDF is allowed. Until your issuing date, PDF invoices to German businesses are allowed with the recipient's consent. After it, PDFs stay valid for consumers, invoices up to €250 and Kleinunternehmer. Other domestic B2B invoices then need a tool that produces XRechnung or ZUGFeRD until Guliel's structured output ships (planned).
- Automate, then migrate. Automations take over routine steps (live). Move the rest over when Guliel covers what you need.
Your Steuerberater stays in the loop. Guliel prepares the records; your accountant reviews and approves them. Invite them as a viewer, or as a contributor if they post journal entries. Captured expenses wait for a person's approval, and a manager sets the books lock date (live). A sign-off queue where an accountant approves AI work is planned. More on working with accountants.
Pricing is per organisation, not per seat. Free is $0 with 200 invoices, 100 expense scans, 10 reports and 5 automations a month. Standard ($20 a month) and Premium ($99 a month) are published prices; paid plans are not on sale yet. See pricing.
FAQ
Do I have to issue XRechnung or ZUGFeRD today?
If you invoice German public authorities, yes: they expect e-invoices, usually XRechnung. For domestic B2B, every business has had to be able to receive e-invoices since 1 January 2025. Issuing becomes mandatory in 2027 for businesses with more than €800,000 turnover in 2026, and in 2028 for every business in scope. Check current BMF guidance for your date.
What is the difference between XRechnung and ZUGFeRD?
XRechnung is XML only, the German profile of EN 16931. ZUGFeRD is a PDF/A-3 with the invoice data embedded as XML, so people read the PDF and systems read the XML. Both meet the B2B mandate; ZUGFeRD needs version 2.0.1 or later and a profile other than MINIMUM or BASIC WL.
Does Guliel generate XRechnung or ZUGFeRD files?
No. Guliel issues German VAT invoices as PDF today. Structured output such as XRechnung, ZUGFeRD and Peppol BIS Billing is planned, with no date yet. Guliel also does not read the XML inside e-invoices you receive; it captures them from the PDF with OCR.
Is Guliel a Peppol access point?
Guliel has built its own Peppol access point and SMP. OpenPeppol certification is pending and the access point is not connected to the app yet, so Guliel does not send or receive invoices over Peppol today.
Is Guliel accounting software or an invoicing tool?
Accounting software. Guliel keeps a double-entry general ledger with manual journal entries, a trial balance, balance sheet, income statement, cash flow, a books lock date and a CSV export. Invoicing, expenses, purchasing, payroll and reports run on the same engine. The chart of accounts is fixed, not SKR03 or SKR04, and there is no DATEV export.
What VAT rate does Guliel apply for Germany?
19% when your organisation is VAT-registered and 0% when it is not. One rate applies per invoice. The 7% reduced rate, mixed rates on one invoice and reverse charge are not supported today.
Can my Steuerberater work with Guliel?
Yes. Invite them with a viewer or contributor role. They get reports as PDF, the ledger as CSV, and expenses as CSV with the source files as a ZIP. Captured expenses wait for a person's approval before they reach the ledger. Guliel does not file VAT or payroll returns.
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