Do freelancers already have to issue e-invoices in 2026?

Not yet mandatorily. But since 1 January 2025 you must be able to receive and process e-invoices. The duty to issue e-invoices yourself applies from 2027 for businesses with over €800,000 prior-year turnover and from 2028 for everyone in the B2B sector. Until then, PDF or paper is still allowed in B2B if the recipient agrees.

What exactly is an e-invoice?

An e-invoice is an invoice in a structured electronic format under the EU standard EN 16931 — such as XRechnung (pure XML) or ZUGFeRD (PDF with embedded XML). A plain PDF is NOT an e-invoice, because it isn't machine-readable.

Does the e-invoice mandate also apply to small businesses (Kleinunternehmer)?

Small businesses under §19 UStG are exempt from the duty to issue e-invoices. But from 2025 they too must be able to receive them — a business customer may send you an e-invoice, and you must be able to process and archive it in a GoBD-compliant way.

Does the e-invoice mandate apply to invoices to private customers?

No. The e-invoice mandate only concerns the B2B sector — invoices between businesses. Invoices to private individuals (B2C), small-amount invoices under €250, and transport tickets are exempt.

E-Invoice Mandate 2026: Guide for Freelancers

“E-invoice” sounds like a PDF by email — but it’s something entirely different. Since 2025, how invoices work between businesses in Germany has been changing, and freelancers and small businesses are affected too. This guide shows what already applies in 2026, what’s coming when, and what you concretely need to do now.

In short: An e-invoice is a structured format under EN 16931 (XRechnung, ZUGFeRD) — a PDF is not enough. You’ve had to be able to receive B2B e-invoices since 1 Jan 2025. You must issue them from 2027 (over €800,000 turnover) or 2028 (everyone). Small businesses are exempt from issuing but must be able to receive. B2C and small amounts under €250 are exempt.

What an e-invoice really is

An e-invoice is not simply a digital image of your invoice. It’s a machine-readable data set under the EU standard EN 16931. Two formats are common in Germany:

XRechnung — pure XML, mainly for public authorities.
ZUGFeRD — a hybrid: a PDF with the XML data embedded. You see a normal invoice; the software reads the data set.

A classic PDF without embedded data does not count as an e-invoice — that’s the most common misconception.

The timeline: what applies when

From	Who	What
1 Jan 2025	all B2B	must be able to receive
1 Jan 2027	turnover > €800,000 (prior year)	must issue
1 Jan 2028	all B2B	must issue

During the transition you may still send PDF or paper in B2B — but only if the recipient agrees. You must be able to receive today.

What this means for you as a freelancer

Now (2025/2026): secure receiving. A business customer may send you an XRechnung or ZUGFeRD file at any time. You need:

An email inbox for receiving (legally sufficient).
A way to read the file — a viewer or accounting software that displays XRechnung/ZUGFeRD.
GoBD-compliant storage — the structured part must be stored unchanged and machine-readable.

Later (2027/2028): switch issuing. By then you’ll need a solution that produces your outgoing invoices in e-format.

Small businesses: relax, but don’t ignore it

If you’re a small business under §19 UStG (see Small business threshold 2026), you’re exempt from issuing. But you too must be able to receive. So at least plan for receiving — ignoring it is not an option.

GoBD: archiving correctly

The structured XML part of an e-invoice must be archived unchanged and machine-readable. The retention period for invoices was shortened from ten to eight years by the Fourth Bureaucracy Relief Act. A PDF printout alone is not enough — it’s about the data set.

Common mistakes

Mistaking a PDF for an e-invoice. Without a structured data set, it isn’t one.
Not preparing to receive. Mandatory since 2025 — even for small businesses.
Storing only the printout. GoBD requires the unchanged XML data set.
Confusing B2C. The mandate doesn’t apply to private customers.

How to keep your VAT under control in general is in VAT for freelancers. And if you’re just starting out: Freelancer registration 2026.

How Restio helps

The e-invoice is a formal requirement, not tax law — but those who sleep on it get trouble with input VAT deduction. Restio puts it in context:

What applies to you? — tell Restio whether you’re a small business and who you invoice, and it tells you whether and from when you’re affected.
Read an invoice — upload a received e-invoice; Restio explains the fields and whether it’s formally correct.
Instant answers — ask in English or German: “Do I have to issue e-invoices as a small business?” or “Is a PDF still enough?”

For choosing and setting up your accounting software, your tax advisor helps — Restio makes sure you know the duties before the first e-invoice lands in your inbox.

The e-invoice arrives in stages, but it arrives for everyone. Those who set up receiving cleanly in 2026 and know the timeline have the transition under control, long before it’s mandatory. The details are in the Federal Ministry of Finance FAQ on e-invoicing.