What exactly is changing in Germany?
Germany has planned the rollout of mandatory electronic invoicing in three steps. Since 1 January 2025, all companies established in Germany must already be able to receive electronic invoices that comply with the European standard EN 16931. That means a machine-readable, structured format: a PDF with a logo does not qualify. From 1 January 2027, the obligation to send structured invoices applies to companies with annual revenue above 800,000 euros. They must then also issue structured invoices themselves for domestic B2B transactions. From 1 January 2028, that sending obligation applies to all companies established in Germany, regardless of revenue. The most widely used formats in Germany are XRechnung and ZUGFeRD, a hybrid format that combines a readable PDF with a machine-readable XML file.
Does the Germany 2027 e-invoicing mandate also apply to Dutch companies?
Not directly. The obligation targets companies established in Germany for their domestic transactions. As a Dutch supplier invoicing a German customer, you formally fall outside the direct scope of the law. In practice, however, it works differently. A large German buyer that must comply with the sending obligation also wants to streamline its incoming invoice process. Many are already requiring suppliers to deliver invoices in a structured format. The de facto market shift is therefore moving faster than the legislation itself. In addition, an EU-wide obligation is coming on 1 July 2030 through ViDA (VAT in the Digital Age): near-real-time reporting of intra-EU transactions will then become the standard. Companies that standardise on a structured format now, preferably via Peppol, will not find themselves scrambling to catch up later.
What does this mean in practice for your invoice processing?
The practical challenge exists on both sides of the invoice flow. On the sending side: if your system still generates PDF invoices, you need to consider when to switch to a structured format. On the receiving side: you will start receiving invoices from German suppliers in XRechnung or ZUGFeRD. These are XML files that cannot simply be opened in your email client. Your accounting system must be able to read and process them. The package you use matters significantly here: Exact, AFAS, Twinfield and others are working on support, but the degree of automated processing varies by package and version. Check this now, not after the first invoice has already arrived.
When is this not a priority?
If you have virtually no business relationships with companies established in Germany, the direct urgency is low. The domestic Dutch B2B mandate has not yet been established either: plans exist, but a concrete effective date for the Netherlands is currently absent. For companies already connected to Peppol in the context of the Belgian mandate or Dutch government procurement, little will change regardless: Peppol networks are already in use in Germany and the rest of Europe. Those parties are the best positioned.
What can you do right now?
Three steps that make sense today. First: assess what share of your revenue runs through German B2B customers and find out whether they already have requirements for invoice format. Second: verify whether your accounting system can receive and process structured invoices in accordance with EN 16931. Third: if your invoice processing is still largely manual, now is the time to address that, rather than waiting until regulation forces your hand. Automatically reading incoming invoices in varying formats (PDF, XML, hybrid) and delivering them into your accounting package or ERP is exactly the kind of document flow that document AI is built for. That way, a new format obligation does not end up meaning someone manually copies data out of an XML file.