Germany's e-invoicing mandate (E-Rechnungspflicht) is the legal obligation, introduced by the Wachstumschancengesetz and written into §14 UStG, for German businesses to exchange invoices for domestic B2B transactions as structured electronic documents conforming to the European standard EN 16931. Receiving e-invoices has been mandatory for every German business since 1 January 2025. Issuing becomes mandatory on 1 January 2027 for businesses whose prior-year turnover exceeded €800,000, and on 1 January 2028 for all B2B transactions. A plain PDF does not qualify. This guide walks Shopify merchants through the full timeline, who is affected and when, and what to set up in 2026 so the deadline is a non-event.
What legally counts as an e-invoice
Since the Wachstumschancengesetz rewrote §14 UStG, German law distinguishes two kinds of invoices:
- E-Rechnung (e-invoice): an invoice issued, transmitted and received in a structured electronic format that conforms to EN 16931 (or an agreed interoperable format). In practice that means XRechnung (pure structured XML) or ZUGFeRD from version 2.0.1 in an EN 16931-compliant profile (a PDF/A-3 file with the invoice data embedded as XML).
- Sonstige Rechnung ("other invoice"): everything else — paper, a plain PDF attached to an email, a JPG scan. Legally, a PDF is now in the same category as paper.
This surprises many merchants: the PDF invoices most Shopify stores email today are not e-invoices under German law. They remain valid only during the transition period, and only with the recipient's consent. If the formats themselves are new to you, our guide ZUGFeRD vs. XRechnung explains both in detail.
The complete timeline
| Date | What changes | What it means for a Shopify merchant |
|---|---|---|
| 1 Jan 2025 | Every German business must be able to receive e-invoices (§27 Abs. 38 UStG transition rules). No consent required from you — a supplier may simply send XRechnung or ZUGFeRD. | Already in force. You need a way to receive and archive structured invoices from suppliers. An email inbox is the accepted minimum channel. |
| 2026 | Transition year: paper and PDF are still allowed for issuing, with the buyer's consent. | The decisive year. Your 2026 turnover determines whether the 2027 issuing obligation hits you. The right year to set up issuing calmly. |
| 1 Jan 2027 | Issuing becomes mandatory for domestic B2B invoices if your prior-year (2026) turnover exceeded €800,000. | Above the threshold, every domestic B2B order must produce an EN 16931 invoice — no consent workaround. |
| 1 Jan 2028 | Issuing becomes mandatory for all domestic B2B transactions, regardless of turnover. | The end state. Every German business invoicing another German business issues e-invoices. |
One nuance worth repeating: the €800,000 threshold is measured against the prior year. Whether you must issue e-invoices from 1 January 2027 depends on your 2026 turnover — which is why 2026 is the year to act, not the year to wait.
Does the mandate apply to your shop?
The issuing mandate covers domestic B2B: both parties are businesses established in Germany. B2C sales are out of scope, and §19 UStG small businesses (Kleinunternehmer) are exempt from issuing — though they, too, must be able to receive.
| Your situation | From 2025 | From 2027 | From 2028 |
|---|---|---|---|
| B2C only (consumers) | Must be able to receive (supplier invoices) | No issuing obligation for B2C sales | No issuing obligation for B2C sales |
| Some B2B, turnover ≤ €800k in prior year | Must be able to receive | May still issue PDF/paper with buyer consent | Must issue e-invoices for domestic B2B |
| Some B2B, turnover > €800k in prior year | Must be able to receive | Must issue e-invoices for domestic B2B | Must issue e-invoices |
| §19 Kleinunternehmer | Must be able to receive | Exempt from issuing | Exempt from issuing (receiving stays mandatory) |
Two practical caveats for e-commerce. First, "B2C only" is rarely literally true: a single wholesale order, a company buying office supplies through your storefront, or a marketplace-adjacent deal makes that transaction B2B. Second, even where no obligation exists, large business customers increasingly request structured invoices because their accounting software ingests them automatically — being able to issue them is becoming a competitive courtesy before it is a duty.
What Shopify provides natively — and what it doesn't
Shopify is excellent at selling and at charging the correct VAT. It was not built to be a German invoicing system, and several things the mandate needs simply do not exist in the platform:
- No EN 16931 output. Shopify's order confirmations and printable receipts are not XRechnung or ZUGFeRD documents, and there is no native e-invoice generator.
- No legal invoice number. The order number (
#1001) is a store reference, not the gapless, never-reused invoice number the GoBD expects. A compliant invoice number sequence has to be created and managed outside Shopify. - No seller tax identity. Your Shopify store profile has no field for your USt-IdNr. (VAT ID), Steuernummer or Handelsregister entry — all of which belong on a German invoice, and some of which EN 16931 marks as mandatory.
- Gross prices need converting. German B2C stores typically sell tax-inclusive. EN 16931 requires net line amounts plus an exact VAT breakdown per rate, so gross prices must be back-computed to the cent — the validators check that the totals reconcile.
- No statutory archive. Shopify retains order data for operations, not as an immutable 8-year tax archive under §147 AO. Archiving is your responsibility (see our guide on GoBD-compliant archiving).
None of this is a criticism of Shopify — invoicing law is national, the platform is global. It does mean the mandate cannot be satisfied with Shopify alone: you need an invoicing layer that reads the order, applies German invoice law, and produces and archives the document. That is precisely the job Rechna was built for: it turns paid Shopify orders into validated ZUGFeRD 2.x and XRechnung 3.x invoices with gapless numbering and a write-once archive, automatically.
How to prepare in 2026
1. Determine your exposure
Estimate your share of domestic B2B orders and your expected 2026 turnover. Above €800,000, your deadline is 1 January 2027; otherwise 1 January 2028. §19 Kleinunternehmer can relax about issuing but should confirm receiving works.
2. Get your seller identity in order
Collect the data every compliant invoice needs and Shopify does not hold: legal company name (not the store name), USt-IdNr. or Steuernummer, full registered address, Handelsregister number, and a contact person — XRechnung requires seller contact details.
3. Fix invoice numbering before the archive fills
Adopt a gapless, chronological invoice number sequence now. Retrofitting numbering is painful; starting clean in 2026 means your archive is coherent from day one.
4. Choose issuing tooling and switch while it's optional
Set up e-invoice generation while PDF is still permitted, so the first mandatory e-invoice is your hundredth, not your first. Verify documents against the official validators (KoSIT for XRechnung, veraPDF for the PDF/A-3 container) — an invoice that fails validation can be rejected by the buyer's system.
5. Sort receiving and archiving
Designate an inbox for inbound e-invoices and archive both inbound and outbound invoices immutably for 8 years (§147 AO, §14b UStG).
Frequently asked questions
Is a PDF invoice still legal at all?
For B2C, yes, indefinitely. For domestic B2B, only during the transition period and with the buyer's consent — until end of 2026 generally, until end of 2027 if your prior-year turnover was at or below €800,000. From 2028, no.
Do foreign sales fall under the mandate?
No. The issuing obligation covers transactions where both parties are established in Germany. Cross-border B2B (intra-EU, exports) follows its own rules — though the EU's ViDA initiative points in the same structured direction.
What happens if I ignore it?
An invoice in the wrong format is not a proper invoice under §14 UStG. The practical risks sit with your buyer's input VAT deduction, with rejection of your invoices by customers' systems, and with findings in a tax audit. "The buyer didn't complain" is not a compliance strategy.
Does the mandate change what must be on the invoice?
The content requirements of §14 Abs. 4 UStG (names, addresses, tax IDs, quantities, net amounts, VAT rates and amounts, invoice number, dates) stay the same — the mandate changes the form: those contents must be machine-readable per EN 16931.
Rechna is software, not tax advice. The rules above are the general framework — how they apply to your specific business is a question for your Steuerberater.