XRechnung for freelancers in the media industry
CueFlow editorial team ·
In short
Since 1 January 2025 every business in Germany, freelancers included, must be able to receive e-invoices. For services to other businesses in Germany, freelancers must issue e-invoices themselves from 2028 at the latest, or from 2027 with prior-year turnover above 800,000 euros. Small businesses and invoices up to 250 euros are exempt.
What an e-invoice is
An e-invoice is an invoice in a structured electronic format that machines can process; as a rule it follows the European standard EN 16931 (Section 14(1) UStG). A PDF file alone is not an e-invoice. XRechnung is such a format. ZUGFeRD combines a readable PDF with the structured data; its MINIMUM and BASIC-WL profiles are not enough for this.
The deadlines
Receiving: since 1 January 2025 for all businesses, without the recipient's consent. Issuing: until the end of 2026, every business may still send paper invoices or, with the recipient's consent, other electronic formats such as a plain PDF. For services in 2027 this only applies if total turnover in the previous year was no more than 800,000 euros. From 1 January 2028 the e-invoice is mandatory between businesses in Germany, apart from the exceptions below (Section 27(38) UStG).
Invoices to private individuals are not affected.
Exceptions
Invoices up to 250 euros gross (small-amount invoices, Section 33 UStDV) may still be issued as other invoices, that is on paper or, with the recipient's consent, as a PDF, for example. The same applies to invoices from small businesses under Section 19 UStG (Section 34a UStDV). They must still be able to receive e-invoices, though.
In practice
Anyone working with studios and production companies mostly invoices businesses. CueFlow creates the invoice straight from the booking as a PDF with embedded ZUGFeRD data in the EN 16931 profile and as an XRechnung; when sending by e-mail, the XRechnung file can be attached as well. Finalised invoices can no longer be changed; corrections are made with a cancellation invoice.
Sources
- Federal Ministry of Finance: questions and answers on mandatory e-invoicing (German)
- Federal Ministry of Finance: letter on the introduction of mandatory e-invoicing (15 October 2025, German)
- Section 14 UStG: issuing invoices (gesetze-im-internet.de, German)
- Section 27(38) UStG: transition rules for e-invoicing (gesetze-im-internet.de, German)
- Section 33 UStDV: small-amount invoices (gesetze-im-internet.de, German)
- Section 34a UStDV: invoices of small businesses (gesetze-im-internet.de, German)