E-invoicing obligations in Germany and Austria: what applies when

Whether the e-invoicing obligation already applies to a given business cannot be answered in general terms. It depends on where the business is established and whom it invoices. Germany and Austria take notably different approaches.

Germany: a three-stage obligation

In Germany, B2B e-invoicing for domestic transactions is now law. The basis is the Growth Opportunities Act (Wachstumschancengesetz) of 27 March 2024 (BGBl. I 2024 No. 108), which introduced the definition of the e-invoice in § 14 (1) UStG and anchored the staged transitional rules in § 27 (38) UStG.

Since 1 January 2025, the statutory definition applies: an e-invoice is an invoice issued, transmitted, and received in a structured electronic format that complies with the European standard EN 16931 (via Directive 2014/55/EU). In practice this amounts to an obligation to receive: because the transitional rules in § 27 (38) UStG concern only issuing, a domestic business recipient can no longer reject a correct e-invoice on the grounds that it did not consent to electronic transmission (the consent requirement under § 14 (1) UStG falls away where the obligation applies). Every domestic business must therefore be able to receive e-invoices, including small businesses.

For issuing, staggered transitional periods under § 27 (38) UStG apply:

Until 31 December 2026, B2B transactions may still be invoiced by other means (paper, or a non-EN-16931-compliant electronic format such as PDF), provided the recipient consents.

Until 31 December 2027, this option remains available, by way of extension, to businesses whose total turnover in the preceding year (2026) did not exceed 800,000 euros.

From 1 January 2028, the e-invoice is mandatory for all domestic B2B transactions.

Formats qualifying as e-invoices include XRechnung as well as ZUGFeRD from version 2.0.1 in its EN-16931-compliant profiles. A plain PDF sent by email does not meet the requirement.

Exemptions

Exempt from the issuing obligation are, among others, small-value invoices up to 250 euros gross (§ 33 UStDV), transport tickets (§ 34 UStDV), certain supplies by small businesses within the meaning of § 19 UStG (§ 34a UStDV), and invoices to private consumers (B2C). In these cases, an “other invoice” remains permissible.

Austria: an obligation only towards the federal government

Austria has no general B2B e-invoicing obligation, and no date for introducing one has been set. The e-invoice is mandatory solely in dealings with the federal government, and has been since 1 January 2014. The legal basis is § 5 of the ICT Consolidation Act (IKT-Konsolidierungsgesetz, IKTKonG) together with the federal e-invoicing regulation (E-Rechnungsverordnung).

Submission is electronic, via the Business Service Portal (USP) and e-rechnung.gv.at, or through the Peppol infrastructure. An important restriction applies: the federal government accepts only structured formats, namely ebInterface and Peppol BIS (UBL). The formats common in Germany, XRechnung and ZUGFeRD, are not accepted. Businesses invoicing both markets therefore need to support more than one format.

For purely domestic Austrian B2B transactions, paper or PDF invoices remain permissible for now.

The EU outlook: ViDA from 2030

Above the national rules sits the EU initiative ViDA (VAT in the Digital Age), adopted as Directive (EU) 2025/516 in March 2025. From 1 July 2030 it introduces an obligation to issue structured e-invoices for intra-Community B2B transactions, that is, invoices between businesses in different member states. Purely national transactions remain a matter for the member states. A national B2B obligation of the kind Germany has introduced could therefore be added in Austria in future.

What this means in practice

Businesses in Germany have had to be able to receive e-invoices since 2025 and should prepare for issuing, depending on prior-year turnover by 2027 or 2028. Businesses in Austria that invoice the federal government or German trading partners already need structured formats now. Regardless of location, switching early avoids time pressure as the deadlines approach.

What an e-invoice actually looks like can be explored at milchrechnung.at: upload a file, and the tool displays its contents in readable form, checks conformity against the official rule sets, and converts between formats as needed. The legal sources are compiled on our sources page.

This article is for general information only and does not constitute legal or tax advice.