In short and in plain language
In Germany, e-invoices between companies are becoming a duty step by step. An e-invoice is an invoice as data that programs can read. This article asks what applies to customers in other EU states.
The German rule only applies if both companies are based in Germany. Customers in other EU states can still get paper invoices. With their consent, a PDF also works.
But take care. Where the goods go does not count. What counts is where the company is based.
Some nearby states have their own rules for their companies. Later, e-invoices will also be the rule between EU states.
Your customer data should show which format each customer gets. We set this up in shop and ERP. The ERP is your program for orders and invoices.
For supplies from 1 January 2027 (Section 27(38) UStG), German companies with prior-year turnover above €800,000 (Section 27(38) UStG) must as a rule issue invoices to other domestic businesses as structured e-invoices, and one year later the rule applies to everyone. Sales teams therefore keep hearing the same question: does the shop also have to send Peppol invoices to business customers in Belgium, France or Poland? The short answer is that the German mandate stops at the border, because it only applies when you and your customer are both established in Germany (Section 14(2) UStG). The longer answer matters more for B2B trade. Several neighbouring countries have introduced mandates of their own, your customers increasingly receive invoices in structured form, and from 1 July 2030 (Directive (EU) 2025/516) the e-invoice becomes the norm for transactions between EU member states as well. This article explains what applies today, where the pitfalls around establishment lie and how shop and ERP control the invoice format per customer country. It is not tax advice.
Key takeaways
- The German e-invoicing mandate only applies when you and your customer are both established in Germany (Section 14(2) UStG). Business customers in other EU states can still be invoiced on paper or, with their consent, as PDF, ZUGFeRD or Peppol BIS.
- Establishment is not the delivery address: if goods go to a German customer’s establishment elsewhere in the EU, the e-invoice remains mandatory (BMF). An involved German branch turns a foreign customer into a domestic one.
- Deadlines apply even without an e-invoicing mandate: an invoice for an intra-EU supply is due by the fifteenth day of the following month (Section 14a(3) UStG), and invoices are kept for eight years (Section 14b UStG).
- Belgium has required e-invoices since 1 January 2026 (einvoice.belgium.be), France reception since 1 September 2026 (DGFiP), Poland issuing via KSeF since 2026 (Ministerstwo Finansów), in each case only for businesses established there.
- From 1 July 2030, e-invoices to EN 16931 become the norm for intra-EU transactions, without the recipient’s consent and with a ten-day deadline for issuing them (Directive (EU) 2025/516).
- The format decision belongs in the customer master: establishment status, invoice format, delivery channel, dated consent and Peppol ID as separate fields, maintained in the ERP and visible in the customer portal.
The German e-invoicing mandate stops at the border
The legal basis is Section 14(2) sentence 2 no. 1 of the German VAT Act (UStG). An invoice to another business for its business purposes must be issued as an electronic invoice if both the supplier and the recipient are established in Germany or in one of the areas listed in Section 1(3) UStG. Only a structured data set that complies with the European standard on electronic invoicing, or that can be fully converted into such a format, counts as an electronic invoice (Section 14(1) UStG). Under this scheme a PDF is an “other invoice”, even when it is sent electronically.
Transition rules soften the switch. For supplies made in 2025 and 2026, every company may still use paper or, with the recipient’s consent, another electronic format, provided the invoice is transmitted by 31 December 2026 (Section 27(38) UStG). For supplies made in 2027 this relief only remains if total turnover in the previous year did not exceed €800,000 (Section 27(38) UStG). EDI invoices remain permitted with consent until 31 December 2027 (Section 27(38) UStG), even if the EDI format does not meet the standard. After that, the mandate covers all domestic B2B supplies. How issuing works technically from shop and ERP is described in our article on the e-invoicing mandate in the B2B shop.
Customers abroad are a different matter. In its letter of 15 October 2025 the Federal Ministry of Finance states: if at least one of the businesses involved in the supply is not established in Germany, there is no obligation to issue an e-invoice (BMF). The invoice can then be issued on paper or, with the recipient’s consent, as an e-invoice or as an other invoice in a different electronic format. This applies to supplies to business customers in other EU member states just as it does to exports to non-EU countries. The table summarises the typical customer situations.
| Customer situation | E-invoice under German law | Permitted formats |
|---|---|---|
| Customer with registered office in Germany | mandatory; transition for 2025 and 2026 supplies for everyone, for 2027 only up to €800,000 prior-year turnover (Section 27(38) UStG) | XRechnung, ZUGFeRD in a compliant profile, agreed interoperable format |
| Customer in another EU state without an involved establishment in Germany | not mandatory (BMF) | paper; electronically as PDF, ZUGFeRD or Factur-X, Peppol BIS only with consent |
| Foreign customer whose German establishment is involved in the supply | mandatory as for domestic customers (Section 14(2) UStG) | as for a customer with registered office in Germany |
| German customer, delivery to its establishment elsewhere in the EU | mandatory, even for a tax-exempt intra-EU supply (BMF) | as for a customer with registered office in Germany |
| Customer in a non-EU country | not mandatory (BMF) | paper; electronically only with consent |
Establishment is more than the delivery address
The shop knows a billing address, a delivery address and usually a VAT identification number. None of these fields decides the e-invoicing question on its own, though; what counts is establishment. A business is established in Germany if it has its registered office, its place of management, a permanent establishment involved in the supply or, in the absence of a registered office, its residence or habitual abode there (Section 14(2) UStG). This leads to three cases that are easy to misclassify in practice because the address data suggests something else.
First, the German customer with a warehouse or plant elsewhere in the EU. The goods cross the border, the supply is a tax-exempt intra-EU supply, and the e-invoice is still mandatory. The Federal Ministry of Finance uses exactly this case as an example: an intra-EU supply from Germany to the establishment of another domestic business in the Community territory (BMF). If you tie the format to the country of the delivery address, this customer receives a PDF although an e-invoice is owed.
Second, the foreign group with a German branch. If the branch places the order and is involved in the supply, the customer is established in Germany within the meaning of the rule, and the domestic mandate applies. What matters is which unit orders and for which unit the supply is intended, not the head office address on the letterhead.
Third, the foreign company that is only registered for VAT in Germany, for example because of a consignment stock. Mere registration is not on the list in the rule; without a registered office, place of management or involved establishment, the customer is not established in Germany according to the wording. Belgium explicitly takes the same approach for the mirror case under its own mandate (einvoice.belgium.be). Agree borderline cases like this with your tax adviser and record the result in the customer master.
The VAT ID says nothing about establishment
What still applies to invoices to other EU states
No e-invoicing mandate does not mean no rules. For an intra-EU supply of goods you must issue the invoice by the fifteenth day of the following month (Section 14a(3) UStG) and state both your own VAT ID and the customer’s. Where the customer owes the tax on a supply in another member state, the invoice must carry the note “Steuerschuldnerschaft des Leistungsempfängers” (reverse charge); for services to businesses the fifteenth day of the following month applies as well (Section 14a(1) UStG). Invoices are kept for eight years (Section 14b UStG), regardless of the format in which they were sent.
The second point is consent. Where there is no mandate, every electronic transmission requires the recipient’s consent; this applies to the structured e-invoice as much as to the PDF sent by email (Section 14(1) UStG). If you keep consent as a field with date and source in the customer master, you can prove it in an audit and also know which format the customer accepts. Without consent, only the paper invoice formally remains.
Public sector buyers in other EU states are a special case. Under EU law they must receive and process electronic invoices that comply with the European standard and one of the approved syntaxes (Directive 2014/55/EU). Whether they also require suppliers to send e-invoices is decided by each country and often by the contract. Our article on public sector buyers in the B2B shop shows what this looks like for German federal authorities.
Eight years of retention, PDFs included
What your customers’ countries require
For German suppliers this is no side issue. According to provisional, calendar and seasonally adjusted figures, goods worth €876.5 billion (Destatis) went to EU member states in 2025, around 56 percent (Destatis) of German goods exports. France was the second most important export destination after the USA with €117.4 billion (Destatis). That Germany does not require an e-invoice for these customers does not mean the customer does not expect one.
Directive (EU) 2025/516 allows member states to require e-invoices from businesses established on their territory without first obtaining authorisation from the Council; they may apply this rule from 14 April 2025 (Directive (EU) 2025/516). Belgium, France and Poland have introduced mandates of their own. The three examples show how different these look, and they share one feature: the mandate only binds businesses established in the country concerned.
Belgium: Peppol since January 2026
Since 1 January 2026 (einvoice.belgium.be) Belgium has required structured e-invoices for transactions between businesses liable to VAT there, usually exchanged over the Peppol network. Businesses without a registered office or permanent establishment in Belgium are not covered, even if they are registered for VAT there. The authority adds, however, that the law is still being amended on this point (einvoice.belgium.be). A second rule matters for German suppliers: anyone who registers on the Peppol network is considered to have agreed to receive structured e-invoices, at least in Peppol BIS format (einvoice.belgium.be). A Belgian customer with a Peppol entry thus shows that it accepts invoices this way; you should still document the consent in the customer master.
France: reception since September 2026
Since 1 September 2026 (DGFiP) all businesses in France, regardless of size and legal form, must be able to receive e-invoices through an approved platform; large and intermediate-sized companies (ETI) have also been issuing them since then. Small and medium-sized enterprises and micro-enterprises follow by 1 September 2027 (DGFiP) at the latest. The scope covers transactions between taxable persons established in France that fall within French VAT and are subject to French invoicing rules (DGFiP). A German supplier without a French establishment is therefore not covered by the mandate. For French customers one format is still the obvious choice: ZUGFeRD and the French Factur-X have been identical since version 2.0 (FeRD). A ZUGFeRD invoice in the right profile is therefore a Factur-X invoice for the customer.
Poland: KSeF since February 2026
Poland has made its central KSeF system mandatory: companies with high sales have been issuing invoices through the system since 1 February 2026 (Ministerstwo Finansów), most of the others since 1 April 2026 (Ministerstwo Finansów). Invoices from taxable persons that have neither a registered office nor a fixed establishment in Poland are exempt (Ministerstwo Finansów). A German supplier therefore continues to invoice its Polish customer outside KSeF. Agree directly with the customer in which form it wants to receive the invoice.
| Country | Mandate since | Applies to | German supplier without establishment | Source |
|---|---|---|---|---|
| Germany | issuing phased in: transition until 31 Dec 2026, for 2027 up to €800,000 prior-year turnover | supplier and customer established in Germany | obliged towards customers established in Germany | UStG |
| Belgium | 1 January 2026 | transactions between businesses liable to VAT in Belgium | not covered; amendment announced | einvoice.belgium.be |
| France | reception 1 September 2026, issuing phased in until 1 September 2027 | transactions between taxable persons established in France | not covered | DGFiP |
| Poland | 1 February 2026, for most others 1 April 2026 | issuing by taxable persons established in Poland | exempt | Ministerstwo Finansów |
Status October 2026
Why customers abroad ask for Peppol anyway
The question usually reaches sales in this form: a customer in Antwerp or Lyon asks to receive invoices via Peppol or as Factur-X in future. For you this is not an obligation. For the customer it saves work, because it receives structured invoices from its domestic suppliers and does not want to key in a PDF by hand for a single supplier from abroad. Peppol is not a file format but a network for transmission. The associated invoice format Peppol BIS Billing 3.0 is a specification of EN 16931; any invoice that complies with it also complies with the European standard (OpenPeppol).
The figures of the EU Payment Observatory, which analyses Eurostat data for the European Commission, show where things are heading. In 2023 only 37 percent (EU Payment Observatory) of small companies in the EU sent e-invoices. In Italy, where the business-to-business mandate entered into force in 2019 (EU Payment Observatory), the share among small companies was 97 percent (EU Payment Observatory) in the same year. Where a mandate applies, customers convert their incoming invoice process, and a supplier sending PDFs becomes the exception in an otherwise automated flow.
To send via Peppol you need a Peppol service provider that connects you to the network; registering directly is not possible (einvoice.belgium.be). The recipient is addressed through its Peppol ID. In Belgium this is at least the company number with scheme ID 0208 (einvoice.belgium.be). This identifier belongs in its own field in the customer master, not in a free-text field of the billing address, otherwise it cannot be transferred reliably into the data set.
From 2030 the e-invoice becomes mandatory across borders
Directive (EU) 2025/516, known as ViDA for “VAT in the Digital Age”, reverses the logic. From 1 July 2030 (Directive (EU) 2025/516) invoices under the VAT Directive are in principle issued as electronic invoices, and they must follow the European standard EN 16931. Member states may still accept paper or other formats for transactions outside the new reporting obligations, but not for intra-EU transactions. A compliant e-invoice will then no longer require the recipient’s consent (Directive (EU) 2025/516).
A shorter deadline comes on top. For intra-EU supplies of goods and for transactions where the customer owes the tax, the invoice must be issued no later than ten days (Directive (EU) 2025/516) after the chargeable event; today the fifteenth day of the following month applies. Instead of the current summary return, each business transmits the data of the individual transaction at the time the invoice is issued (Article 263 VAT Directive as amended by Directive (EU) 2025/516). Member states transpose these rules into national law; the details for Germany will follow from the implementing act.
On request today, standard from 2030
Format control per customer country in shop and ERP
Technically everything comes down to one decision per invoice: which format, which channel, which mandatory details. This decision does not belong in the accounting team’s memory or in a special rule in invoice printing, but in the customer master. The ERP holds the values, shop and B2B customer portal display them and let customers maintain, for example, their e-invoice address themselves, and invoice generation reads them. Six fields carry the logic.
Establishment
Established in Germany yes or no, with the reason: registered office, management or involved establishment. Maintained separately from billing and delivery address.
Invoice format
XRechnung, ZUGFeRD or Factur-X, Peppol BIS or PDF. For customers established in Germany only compliant formats can be selected.
Delivery channel
Invoice email address, customer portal, EDI connection or Peppol with identifier. One clearly named channel per customer instead of a shared mailbox.
Consent
Whether and when the customer agreed to the electronic format, with date and source, such as framework agreement, email or Peppol entry.
Identifiers
Peppol ID with scheme, buyer reference, customer order number and VAT ID as separate fields so they reach the invoice in structured form.
Deadline rule
Issuing deadline per transaction type as a setting: today the fifteenth day of the following month for intra-EU supplies, from 2030 ten days.
At the core sits a format layer that produces different outputs from the same order data: an XRechnung for the customer in Hanover, a ZUGFeRD invoice in the EN 16931 profile for the customer in Lyon, a Peppol BIS invoice for the customer in Ghent and a PDF for the customer in Kraków who has agreed nothing else. Because the structured formats share the EN 16931 data model, the effort for an additional format stays manageable as long as the data is complete. We implement XRechnung and ZUGFeRD generation from shop and ERP as part of our shop and ERP integrations; any further format draws on the same data.
Key accounts that already order and receive invoices via EDIFACT stay on their channel. The transition rule for EDI invoices until the end of 2027 only concerns customers covered by the domestic mandate anyway; for customers abroad, the agreement alone counts. How EDI is connected to the shop is explained in our article on EDI in the B2B shop.
Invoice data that works across borders
A format is only as good as the data in it. With invoices to customers abroad, processing at the customer’s end typically fails not because of the XML but because of missing details that its system needs for automatic matching. These points belong on the checklist before the first structured invoice goes to a customer abroad.
- The customer’s VAT ID and your own, required for intra-EU supplies (Section 14a(3) UStG)
- A note on the tax exemption or on the reverse charge, both as text and as tax category in the data set
- The customer’s order number and buyer reference from checkout, so its system can match the invoice to the order
- Unit codes and invoice language, so quantities can be posted without queries
- Attachments such as delivery note or test certificate through the same channel as the invoice, for example embedded in the data set, instead of a separate email; Belgium explicitly requires the same channel for invoices within its own mandate (einvoice.belgium.be)
- Validation against schema and business rules of the standard before sending, with feedback to accounting in case of errors
Many of these details originate in the ordering process. If checkout does not ask for the customer’s order number, the invoice cannot carry it. That is why format control belongs in a Shopware project with ERP integration and not only in the accounting software. How country shops with their own language, price list and tax logic are built is described in our article on B2B internationalisation with country-specific shops.
Five steps to an invoice flow ready for other countries
The changeover can be cut so that the domestic mandate is met first and the ability to serve customers abroad comes without a second project. The order follows the deadline that applies to your turnover size.
- Analyse the customer master: which customers are established in Germany, which have an establishment in Germany or order for sites abroad, which are only registered here?
- Create fields: maintain establishment status, invoice format, delivery channel, dated consent and Peppol ID in the ERP and display them in the customer portal.
- Implement the domestic mandate: generate XRechnung and ZUGFeRD from order data, validate before sending and test well ahead of the deadline for your turnover class.
- Ask customers abroad: who wants Peppol, Factur-X or continues with PDF? Collect consents, store them in the master data and set up a Peppol connection only where there is real demand.
- Plan ahead for 2030: keep deadlines per transaction type as a setting so that the switch to ten days and to transaction-level reporting remains a matter of configuration.
Where your company stands in these steps and which fields already exist in your ERP is something we clarify in an e-commerce consultation. The scope of the technical implementation is shown on our page on e-invoicing in the B2B shop.
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