How long must invoices be retained in Germany?

German law (§ 257 HGB and § 147 AO) requires 8 years of retention for invoices and related accounting documents. The archived document must remain unchanged and verifiable for the entire retention period.

EU E-invoicing overview

B2G live since 2020 / B2B from 2025

E-invoices for Germany. Without complicated accounting software.

Q: What is the difference between XRechnung and ZUGFeRD?

XRechnung is a pure XML format (UBL or CII syntax) used primarily for B2G invoicing and EDI pipelines. ZUGFeRD is a hybrid format: a PDF/A-3 file with embedded XML. Both implement EN 16931. For human readability, ZUGFeRD is often preferred. For machine processing and B2G submissions, XRechnung is the standard.

Create XRechnung and ZUGFeRD in the browser, including as a Kleinunternehmer. SealDoc checks every invoice against the German rules before it is created. An invoice that does not pass is never made.

Start free Check an XRechnung

Free for up to 5 invoices a month.

Standard

XRechnung / ZUGFeRD

Legal basis

Wachstumschancengesetz

Receive obligation

Jan 1, 2025

Send obligation

2027 / 2028

What SealDoc does for you

XRechnung 3.0

In CII, as a PDF/A-3 with the XML inside. You download the bare XML separately, for the federal government platform.

ZUGFeRD

BASIC profile: a PDF/A-3 with the XML inside. Readable for your customer, processable by their accounting, valid for B2B.

Kleinunternehmer (§ 19 UStG)

Choose the exemption and SealDoc puts “Steuerfreier Kleinunternehmer gemäß § 19 Abs. 1 UStG” on the invoice and in the XML.

Leitweg-ID

Record it once with your customer. SealDoc puts it in field BT-10 of every XRechnung to that customer.

Every invoice passes the schema check and the EN 16931 rules, and an XRechnung also the German XRechnung rules. What does not pass is not created.

From the browser or from your own software

In the browser

SealDoc Invoice: choose your customer, fill in the lines, pick XRechnung or ZUGFeRD. Free for up to 5 invoices a month.

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From your own software

The API: send JSON and get a checked XRechnung, ZUGFeRD or Peppol BIS 3.0 invoice back. In the paid plans.

Go to the API

Mandate timeline

Live

27 Nov 2020

B2G mandatory (federal)

Suppliers to federal authorities must invoice electronically (ERechV § 3 Abs. 1, in force since 27 November 2020 via § 11 Abs. 3). Direct orders (Direktaufträge) up to 1,000 EUR are exempt (ERechV § 3 Abs. 3 Nr. 1). Since September 2025, federal authorities receive invoices through a single platform, OZG-RE.

Live

1 Jan 2025

B2B receive obligation

Every business based in Germany, including Kleinunternehmer, must be able to receive structured e-invoices. XRechnung and ZUGFeRD from version 2.0.1 both qualify, except the ZUGFeRD profiles MINIMUM and BASIC-WL.

Upcoming

1 Jan 2027

B2B send (over 800k EUR turnover)

Businesses whose total turnover in the previous year was above 800,000 EUR must send structured e-invoices. Below that threshold, the transition rule runs until 31 December 2027.

Upcoming

1 Jan 2028

B2B send (all other businesses)

All other businesses based in Germany must send structured e-invoices to business customers. The exceptions below still apply.

Exceptions: small-amount invoices up to 250 EUR (Kleinbetragsrechnungen, § 33 UStDV), tickets for passenger transport (§ 34 UStDV) and invoices from Kleinunternehmer (§ 34a UStDV) may always be issued in another format. Invoices to consumers fall outside the obligation altogether.

XRechnung vs ZUGFeRD: which do you need?

Both formats implement EN 16931 and are legally equivalent for B2B purposes under the Wachstumschancengesetz. For ZUGFeRD this applies from version 2.0.1, except the MINIMUM and BASIC-WL profiles. The difference is in structure and use case.

XRechnung

+ Pure XML (UBL or CII syntax), ideal for EDI pipelines
+ Standard for invoices to the federal administration (ERechV); the Länder have their own rules
+ To federal authorities via the OZG-RE platform, over four channels: web entry (Weberfassung), upload, Peppol or email
- Not human-readable without a viewer
- Requires Leitweg-ID for public sector recipients

Validate an XRechnung file →

ZUGFeRD / Factur-X

+ PDF/A-3 with embedded XML: readable by humans and machines
+ Drop-in for existing PDF invoice workflows
+ Accepted for B2B from version 2.0.1, except the MINIMUM and BASIC-WL profiles (Wachstumschancengesetz)
- Larger file size than pure XML
- The federal platform OZG-RE accepts only pure XML without a visual PDF part and gives ZUGFeRD in the XRECHNUNG profile as an example. A hybrid PDF is not accepted there.

Validate a ZUGFeRD / Factur-X file →

Peppol BIS Billing 3.0

Peppol BIS 3.0 for Germany, independently verified.

SealDoc creates Peppol BIS 3.0 invoices and credit notes with a German seller and buyer. Before it is created, every invoice goes through EN 16931, the Peppol rules and the German rules (DE-R). An independent validator with the official OpenPeppol rules 3.0.21 confirmed it: an invoice at 19%, one with 19% and 7%, and a credit note, all valid.

Sending via Peppol: soon directly from SealDoc. We are completing the final steps of the connection.

DE-R

What the German rules additionally require

Buyer reference (BT-10)
Seller contact with name, phone and email
Payment instructions (BG-16)
VAT rate per category (BT-119)
Skonto in the prescribed format

What the German rules require Create them through the API

Leitweg-ID: the German public sector routing identifier

Every German public authority has a Leitweg-ID, a structured routing identifier. It consists of a Grobadressierung (2 to 12 characters), an optional Feinadressierung (up to 30 characters) and a check digit (Prüfziffer) calculated with Modulo 97-10. XRechnung invoices destined for a public buyer must carry the Leitweg-ID in field BT-10 (buyer reference).

The Leitweg-ID belongs in BT-10. Without BT-10, an XRechnung fails the mandatory rule BR-DE-15 (fatal). The receiving platform also cannot route the invoice to the right office.

Leitweg-IDs are public and can be looked up in the official register. Many German municipalities list their Leitweg-ID on their website under the "Lieferanteninformationen" (supplier information) section.

8-year retention: § 257 HGB and § 147 AO

Legal requirement

§ 257 HGB and § 147 AO require businesses to retain invoices for 8 years from the end of the fiscal year in which the invoice was created.

The archived document must be stored in a way that ensures it cannot be altered (tamper-evidence) and can be retrieved and verified at any time during the retention period.

What SealDoc records with every invoice

PDF/A-3, the ISO standard for documents that must stay readable for a long time
A SHA-256 hash at the moment of creation: change one byte and the hash no longer matches
The XML, downloadable separately for your own records

Frequently asked questions

Is XRechnung mandatory for B2B invoices in Germany?

From 1 January 2025, every business based in Germany, including Kleinunternehmer, must be able to receive structured e-invoices (XRechnung, or ZUGFeRD from version 2.0.1 except the MINIMUM and BASIC-WL profiles). The obligation to send structured invoices applies to businesses with over 800k EUR annual turnover from 1 January 2027, and to all other businesses based in Germany from 1 January 2028, with exceptions such as small-amount invoices and Kleinunternehmer.

Can I still send a plain PDF invoice to a German company?

Until 31 December 2026, yes. Invoices may be issued on paper or, with the recipient's consent, in another electronic format. Until 31 December 2027 this still applies to issuers whose total turnover (Gesamtumsatz) in the previous year was no more than 800,000 EUR. From 1 January 2028, the obligation applies to all other businesses based in Germany, with exceptions such as small-amount invoices and Kleinunternehmer. Receiving is a separate matter. Since 1 January 2025, every domestic business must be able to receive an e-invoice, and an email inbox is enough (BMF FAQ).

What is the difference between XRechnung and ZUGFeRD for B2B?

For B2B invoicing under the Wachstumschancengesetz, both are legally equivalent: any EN 16931-compliant format is accepted. For ZUGFeRD this applies from version 2.0.1, except the MINIMUM and BASIC-WL profiles. XRechnung is pure XML (better for EDI), ZUGFeRD is a hybrid PDF with embedded XML (better for human readers). The federal platform OZG-RE accepts only pure XML; for ZUGFeRD it gives the XRECHNUNG profile as an example.

What is the Leitweg-ID and do I need it?

The Leitweg-ID is a routing identifier used by German public authorities (municipalities, federal agencies, state governments). It must be included in field BT-10 of an XRechnung invoice sent to a public sector buyer. It is not required for B2B invoices.

How long must I retain invoices in Germany?

German law (§ 257 HGB and § 147 AO) requires 8-year retention from the end of the fiscal year. The archived document must be tamper-proof and retrievable for the full period. In practice this means the original file plus a cryptographic hash or RFC 3161 timestamp that proves the file has not changed.

Can I create e-invoices with SealDoc as a Kleinunternehmer?

Yes. You are not required to (§ 34a UStDV), but you may, and since 2025 your business customers must be able to receive them. Choose VAT category E with § 19 as the ground, and SealDoc puts the exemption text on the invoice and in the XML.

Create your first XRechnung today.

Free for up to 5 invoices a month. Or check an existing file first, no account needed.

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