E-invoices (E-Rechnung) for artists and freelancers: the 2025–2028 transition

Page last checked: 2026-09-28

The Federal Ministry of Finance (Bundesfinanzministerium) describes the e-invoice (E-Rechnung) for supplies between businesses established in Germany and expressly names freelancers (Freiberufler) in its FAQ. Whether and from when this applies to you is answered by your tax adviser. Here is what the ministry says about the transition, and what an XRechnung is.

Who the e-invoice concerns

The Federal Ministry of Finance (Bundesfinanzministerium) describes the e-invoice „bei Umsätzen zwischen inländischen Unternehmern“ — for supplies between businesses established in Germany. According to its FAQ, a business (Unternehmer) is „wer eine gewerbliche oder berufliche Tätigkeit selbständig ausübt (§ 2 UStG)“ (anyone who carries on a commercial or professional activity independently); the FAQ expressly include freelancers (Freiberufler) and Kleinunternehmer. Whether and from when this applies to you is answered by your tax adviser.

Even where an invoice has to be issued, according to the same FAQ it need not be an e-invoice in certain cases — among them small amounts (Kleinbeträge, §33 UStDV), tickets that count as invoices (Fahrausweise, §34 UStDV) and supplies by Kleinunternehmer (§34a UStDV).

Invoices to consumers are not covered — according to the FAQ, „private Endverbraucher … von diesen Regelungen nicht betroffen“ (private end consumers are not affected). Invoices to public authorities are subject to separate rules on electronic invoicing to public contracting bodies.

The transition from 2025 to 2028

Transition rules for the e-invoice according to the Federal Ministry of Finance FAQ
Period	Receiving	Issuing
since 1 January 2025	Every business in Germany must be able to receive e-invoices; an email inbox is enough.	Instead of an e-invoice, another invoice (sonstige Rechnung) is allowed: paper always, another electronic format (such as a PDF by email) only if the recipient agrees.
1 January to 31 December 2027	as before	Another invoice remains allowed if the issuer's prior-year turnover is no more than €800,000.
from 1 January 2028	as before	The e-invoice is mandatory for supplies between businesses established in Germany.
Kleinunternehmer (§19 UStG)	must be able to receive e-invoices	are exempt from issuing e-invoices

The first transition rule applies to every issuer in 2025 and 2026. Whether you are a Kleinunternehmer and which turnover counts for it is a tax question about your individual case; your tax adviser answers it, not this page.

What counts as an e-invoice — and what does not

Since 1 January 2025 an e-invoice is only an invoice in a structured electronic format that allows electronic processing. According to the Federal Ministry of Finance a plain PDF is not one, because it has no structured format. The standard is the European norm EN 16931; the FAQ name the formats usual in Germany, XRechnung and ZUGFeRD.

According to the same FAQ, an e-invoice must be kept for eight years under §14b(1) UStG, at least its structured part in its original form. More on the periods in Record retention periods.

XRechnung: UBL or CII, checked with the KoSIT validator

XRechnung is the German standard developed by the Koordinierungsstelle für IT-Standards (KoSIT) and published on xeinkauf.de. Version 3.0 has been in force since 1 February 2024; the current specification is 3.0.2. Two syntaxes are allowed: UBL 2.1 and CII. An XRechnung is a pure XML file without a PDF view; a viewer makes it readable, for example the e-invoice viewer in the ELSTER portal.

Whether a file meets the norm and the business rules is checked by KoSIT's open-source validator. According to the Federal Ministry of Finance, validation is not a direct condition for recognition for tax purposes, but it helps to find missing or inconsistent mandatory details.

Frequently asked questions

From when does the e-invoice apply, according to the Federal Ministry of Finance?

According to the Federal Ministry of Finance, businesses established in Germany must be able to receive e-invoices since 1 January 2025. For issuing, the ministry names transition rules: in 2025 and 2026 every issuer may still use another invoice (sonstige Rechnung), and in 2027 too if prior-year turnover is no more than €800,000; after that the e-invoice is mandatory for supplies between businesses established in Germany. Whether and from when this applies to you is answered by your tax adviser.

Do Kleinunternehmer have to be able to receive e-invoices?

Yes. According to the Federal Ministry of Finance, Kleinunternehmer are exempt from issuing but must be able to receive e-invoices since 1 January 2025; an email inbox is enough. Whether someone is a Kleinunternehmer is a question for a tax adviser.

Is a PDF invoice an e-invoice?

No. Since 1 January 2025 an e-invoice is only an invoice in a structured electronic format; according to the Federal Ministry of Finance a plain PDF is another invoice (sonstige Rechnung). During the transition years it remains allowed if the recipient agrees.

What is the difference between XRechnung in UBL and in CII?

Both are permitted XML syntaxes of XRechnung 3.0 (current specification 3.0.2, in force since 1 February 2024). The content follows the same norm, EN 16931, and the KoSIT validator checks both.

Sources

By the Künstlerfinanzen editorial team. Page last checked: 2026-09-28. The information comes from:

This text reproduces the wording of the statute and official information. It is not legal advice and not tax advice. What applies in your case is answered by your tax adviser, the Künstlersozialkasse or an adviser of your choice.