E-invoicing in Germany for agencies: XRechnung and ZUGFeRD

When does your agency have to send e-invoices? If your agency and your business client are both in Germany: from 1 January 2027 when your 2026 turnover was over €800,000, and from 1 January 2028 in any case. Receiving them has been required since 2025. Sumhour makes an XRechnung and a ZUGFeRD file from every sent invoice, in every plan.

Checked against the law text (§ 14 and § 27 UStG, § 33 and § 34a UStDV) on November 5, 2026. This page explains the rules; it is not tax advice.

The dates

The duty covers invoices between two businesses established in Germany. "Established" means a seat, management or a permanent establishment involved in the work (§ 14 (2) UStG).

Who does not have to send them

• Invoices of €250 or less in total (§ 33 UStDV).
• Small businesses under § 19 UStG, the Kleinunternehmer rule (§ 34a UStDV).
• Invoices to private people.
• Agencies outside Germany. A UK or Dutch agency billing a client in Berlin is not covered, though the client may still ask for an e-invoice to process it faster.

Everyone in Germany still has to be able to receive e-invoices from suppliers.

XRechnung or ZUGFeRD

The law asks for an invoice that follows the European standard EN 16931. Two formats are used for it in Germany. XRechnung is a structured XML file; public bodies require it, with the Leitweg-ID as the buyer reference, and many larger companies prefer it.ZUGFeRD is a PDF a person can read, with the same data inside as XML, which suits clients who still open invoices by eye. ZUGFeRD counts only in a profile that meets EN 16931; the MINIMUM and BASIC-WL profiles do not.

Sumhour makes XRechnung 3.0 and ZUGFeRD in the EN 16931 profile from the same sent invoice, so you send the one the client asks for.

A worked example

Fieldwork, a business in Berlin, receives INV-1042 for 36 hours at 125.00: 4,500.00. In Sumhour the invoice is built from the tracked time, sent, and then its E-invoice panel offers "ZUGFeRD PDF" and "XRechnung XML". If anything the formats need is missing, such as your IBAN, a contact phone or the client’s postcode, the panel names it before the download. The client’s own invoice page offers both files too, and the invoice email can carry one.

See e-invoicing in Sumhour · Set it up in the guide

Setting it up in Sumhour

1. Open Invoice settings, then "E-invoices": your street, postcode, city and country, your VAT id or tax number (Steuernummer), a contact name and phone, and your IBAN.
2. On each client, expand "E-invoice details": their address and country, their VAT id for an EU business, and the Leitweg-ID under "Buyer reference" for a public body.
3. Send the invoice as usual. The E-invoice panel shows how VAT is treated (standard, reverse charge, outside the scope, exempt or Kleinunternehmer) and offers both files.

Limits: an e-invoice carries one VAT rate and no second tax, and drafts have no e-invoice until they are sent.

Questions

Does my agency have to send e-invoices to German clients?

Only if both your agency and the client are established in Germany and the client is a business. A German agency with more than €800,000 turnover in 2026 must send them from 1 January 2027; every German agency from 1 January 2028. An agency outside Germany is not covered by the duty, though a German client may still ask for an XRechnung.

Is a PDF invoice by email still allowed?

Until the end of 2026, yes, if the client agrees. In 2027 only for businesses with turnover up to €800,000 in 2026. From 2028 a plain PDF no longer counts as an invoice between German businesses, except the small cases below.

Which invoices are exempt?

Invoices of €250 or less in total, and invoices from small businesses under § 19 UStG (Kleinunternehmer), can always be sent as a normal invoice. Invoices to private people are not covered. Every business still has to be able to receive e-invoices.

XRechnung or ZUGFeRD: which one should I send?

Both meet the European standard EN 16931 that the law asks for. XRechnung is an XML file, which public bodies and many larger companies expect. ZUGFeRD is a PDF a person can read with the same data inside, handy for smaller clients. Sumhour makes both from every sent invoice, so you can send whichever the client asks for.

Does Sumhour check the files?

Yes. Our build checks sample invoices against the official German validator (KoSIT, XRechnung 3.0.2) and every ZUGFeRD PDF with the Mustang validator, and fails if one is rejected. In the app, the invoice’s E-invoice panel lists anything missing before you download, such as your IBAN or the client’s address.

Sources

• § 14 UStG, invoices and the e-invoice duty between businesses established in Germany:gesetze-im-internet.de, read November 5, 2026.
• § 27 (38) UStG, the transition to the end of 2026 and 2027 and the €800,000 threshold:gesetze-im-internet.de, read November 5, 2026.
• § 33 UStDV, invoices up to €250, and § 34a UStDV, Kleinunternehmer invoices:§ 33,§ 34a, read November 5, 2026.
• XRechnung versions:xeinkauf.de, read November 4, 2026.

Also see e-invoicing in Belgium (Peppol).