E-Invoicing for Freelancers in Germany: When Is It Mandatory?

As a freelancer you must be able to receive e-invoices since 1 January 2025. You must issue them when you bill another business in Germany, and a transition period applies (§ 14 Abs. 2 Satz 2 Nr. 1 UStG, § 27 Abs. 38 UStG). The duty does not apply to private clients or clients abroad.

Last updated: 29 October 2026

In short

  • Receiving: Since 1 January 2025 for all German businesses; an email inbox is enough.
  • Issuing: Mandatory for services to German businesses; transition periods run until 31 December 2027.
  • Exceptions: Private clients, foreign clients, exempt medical treatment and small businesses.

Do I have to issue e-invoices as a freelancer?

Yes, if your client is a business and both of you are established in Germany. Then the invoice must be issued as an electronic invoice under § 14 Abs. 1 Satz 3 and 6 UStG (§ 14 Abs. 2 Satz 2 Nr. 1 UStG). An electronic invoice is an invoice in a structured electronic format that allows electronic processing (§ 14 Abs. 1 Satz 3 UStG). A simple PDF does not qualify according to the BMF; XRechnung and ZUGFeRD from version 2.0.1 (without the profiles MINIMUM and BASIC-WL) meet the requirements. The duty does not apply to turnover exempt under § 4 Nr. 8 to 29 UStG, for example medical treatment (§ 4 Nr. 14 UStG).

Your clientE-invoice mandatory?
Business in Germanyyes, after the transition period
Private personno, paper or PDF is enough
Business abroadno, the duty requires both sides to be established in Germany
Service exempt under § 4 Nr. 8 to 29 UStGno

What this means for you: If you bill business clients in Germany, you switch to e-invoices; for private and foreign clients nothing changes.

By when do I have to switch?

The Act sets a transition period by the date the supply is made (§ 27 Abs. 38 UStG):

Supply made inWhat applies to the invoice
2025 or 2026paper or, with the recipient's consent, another electronic format such as PDF, if you send it by 31 December 2026
2027, your total turnover last year at most 800,000 eurospaper or, with the recipient's consent, PDF, if you send it by 31 December 2027
2027 above 800,000 euros last-year turnover, or from 2028e-invoice, except for example small amounts up to 250 euros (§ 33 UStDV)

What matters is when the supply was made, plus the date you send the invoice. A paper or PDF invoice for a service from December 2026 that you send only in January 2027 is no longer covered by § 27 Abs. 38 Nr. 1 UStG. The full overview for traders: E-invoice obligation 2027.

What this means for you: Most freelancers are below 800,000 euros; for them the cut-off for 2027 services is 31 December 2027. Plan the switch for January 2028 at the latest.

Do I have to receive e-invoices too?

Yes, since 1 January 2025 German businesses must be able to receive an e-invoice; the BMF provides no exceptions. In practice your email inbox is enough. An XRechnung is an XML file and needs a viewer, which the tax administration offers at e-rechnung.elster.de; how to read and check invoices is in Receive and read e-invoices. You must keep incoming and outgoing invoices for eight years (§ 14b Abs. 1 UStG).

What this means for you: Set up an inbox you check regularly and keep the file, not only a printout.

Does the duty apply if I am a small business?

You do not have to issue an e-invoice then, but you must receive them. That is explained in E-invoicing for small businesses.

What this means for you: As a small-business freelancer you need not issue an e-invoice, but you must be able to receive one.

How VAT GPT helps

  1. Fill in: On the Income page, open the entry "Create invoice" in the "Tips" card and pick ZUGFeRD (PDF) or XRechnung (XML) under "Format".
  2. Check: Review the details on the invoice.
  3. Send: Download the file. VAT GPT reads incoming ZUGFeRD PDFs and XRechnungen when you upload them.

There are Free, Go (30 days free with all Pro features) and Pro. Try it for free

Frequently asked questions

Do I have to write an e-invoice from 2027 as a freelancer? For services to German businesses made in 2027: with at most 800,000 euros turnover last year, paper or PDF with the recipient's consent is still possible until 31 December 2027, with more turnover it is not (§ 27 Abs. 38 UStG).

Do I need an e-invoice for private clients? No; the duty applies to services to other businesses (§ 14 Abs. 2 Satz 2 Nr. 1 UStG).

Does the duty apply to clients abroad? No; it requires that issuer and recipient are established in Germany (§ 14 Abs. 2 Satz 2 Nr. 1 UStG).

How long do I have to keep invoices? Eight years (§ 14b Abs. 1 UStG).

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No tax advice: this content does not replace individual advice.

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