the Obligation to accept Since January 1, 2025, every domestic entrepreneur is required to be able to receive electronic invoices. There is neither a transitional provision nor any exceptions for the receipt obligation (BMF letter of 2024, paragraphs 14, 40, 62; FAQ 8 and 12).
Who is subject to the reception obligation
The requirement applies to domestic B2B sales. For this purpose, both entrepreneurs must be established in the country (BMF letter 2024, p. 13). If at least one of the parties is not established in the country, there is no obligation to issue an e-invoice (p. 16). Entrepreneurs explicitly include freelancers and individuals with exclusively tax-free sales, such as landlords, small business owners, or doctors (FAQ 3). These groups are not required to issue an e-invoice. However, they must be able to receive e-invoices (FAQ 12). A association, on the other hand, must neither receive nor issue invoices insofar as the services relate to its non-business activities (FAQ 5).
What the reception technically requires
A normal email mailbox is sufficient. A separate mailbox is not necessary, and the recipient does not have to agree. For the human-readable display of an XInvoice, the recipient needs a viewer software. The financial administration offers an XInvoice viewer for E-Rechnung and ZUGFeRD via the ELSTER portal: www.e-rechnung.elster.de (FAQ 12a).
Consequences of a refusal to accept
If the recipient refuses to accept the e-invoice or is unable to receive it technically, they are not entitled to an alternative other invoice. The issuer fulfills its VAT obligations by issuing an e-invoice and proving its efforts to transmit it, for example by providing a transmission record (BMF letter 2024, paragraph 42; BMF letter 2025, section 14.1, paragraph 5).
Distinction from the exhibition obligation
The receipt obligation differs from the exhibition obligation. Transitional deadlines apply until the end of 2027 for exhibition, depending on the previous year’s turnover (BMF letter 2024, paragraphs 63 to 65). There is no such deadline for receipt.
Legal status: MF Treasury letter 2024 and 2025, MF Treasury FAQ as of March 2026.
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