Whether IT consultant, graphic designer, copywriter, translator, business consultant, or photographer – freelancers and the self-employed are affected by the German e-invoicing mandate just as much as large companies. The difference lies in the timeline and the available tools. This guide explains concretely what freelancers and self-employed people must do now, what comes later, and which tools are genuinely suited to solo operations.
Am I Affected as a Freelancer?
Yes – if as a freelancer or self-employed person you issue invoices to other businesses (B2B) that are established in Germany. The e-invoicing mandate applies to all domestic B2B transactions under § 14 UStG, regardless of legal form. As a freelancer (Freiberufler in the tax law sense under § 18 EStG) you are just as affected as a commercial sole trader.
The Deadlines for Freelancers at a Glance
- January 1, 2025: You must be able to receive e-invoices from other businesses. This applies to you as a freelancer too – if a supplier sends you an XRechnung, you cannot refuse it.
- January 1, 2027: Sending obligation for freelancers with annual turnover above €800,000. Most individuals and small offices do not reach this threshold.
- January 1, 2028: Sending obligation for all freelancers and self-employed persons, regardless of turnover. Even someone earning only €20,000 per year must then issue e-invoices.
Small Businesses (§ 19 UStG): Special Features
Many freelancers use the small business scheme under § 19 UStG: anyone with turnover below €22,000 in the previous year and expected below €50,000 in the current year can waive the showing of VAT. What does this mean for the e-invoicing obligation?
- The e-invoicing obligation also applies to small businesses as soon as they invoice other businesses – i.e. from 2028.
- In the e-invoice, VAT is shown as exempt: tax category E, tax rate 0%, BT-120 (exemption reason) referencing § 19 UStG.
- Instead of the VAT ID (BT-31), the tax number (BT-32) can be stated – which you received from the tax office.
- Notice text on the invoice: The reference to the small business scheme is still required – in the e-invoice format as an invoice note (BT-22) or in BT-120.
Which Invoices Must Freelancers Issue as E-Invoices?
As a rule of thumb: every invoice to a business established in Germany – from the mandatory dates. Specifically:
- E-invoice required: Projects for GmbH, AG, UG, OHG, KG, GbR, sole traders, freelancers (other self-employed).
- E-invoice NOT required: Projects for private individuals (even if they work from home), associations without commercial activity, foreign companies.
- Borderline case: If you are not sure whether your client is a business within the meaning of VAT law – ask for their VAT ID or tax number.
Government Clients: E-Invoice Already Mandatory Now
If you already work for federal ministries, federal agencies, state authorities, or municipalities, the XRechnung obligation applies to you already – since the ERechV 2019. You must submit XRechnung to the ZRE (federal) or the relevant state portals, including the Leitweg-ID.
The Best Tools for Freelancers
- Our XRechnung Generator (free): Creates compliant UBL XML files directly in the browser. No registration, no data sharing. Ideal for occasional invoices.
- Sevdesk: Cloud-based accounting software with ZUGFeRD export. Entry tier from about €8/month.
- Fastbill: Similar to Sevdesk, with a good mobile app. XRechnung support in development.
- Lexoffice (Haufe): Popular solution for freelancers, with ELSTER integration and ZUGFeRD export.
- DATEV Mittelstand faktura: For freelancers with a DATEV tax advisor – seamless integration with bookkeeping.
Practical Preparation Plan for Freelancers
- Now: Set up an email inbox for receiving e-invoices (or use an existing address) and ensure your tax advisor can import XML invoices.
- By end of 2025: Evaluate accounting software – can it export ZUGFeRD or XRechnung?
- By end of 2026: Switch to e-invoice-capable software (if not already done). Create and validate test invoices.
- From 2027 or 2028 (depending on turnover): Only send e-invoices for B2B customers in Germany.
- Ongoing: Archive all issued and received e-invoices as original XML files for 10 years in GoBD-compliant manner.
Fee Invoices with Flat Rates
Many freelancers issue simple flat-rate invoices: one line item, one total price. This can easily be represented as XRechnung – one line (BG-25) with service description, quantity 1, unit HUR (hours) or C62 (piece), unit price = total fee. Tax category S at 19% for VAT-liable freelancers or E at 0% for small businesses.
Foreign Invoices: No E-Invoice Obligation
If as a freelancer you work for businesses abroad (EU or third countries), the German e-invoicing obligation does not apply. These invoices can continue to be issued as PDF or in any format – although the client's country may have its own e-invoicing requirements.
Frequently Asked Questions from Freelancers
Must I issue my invoices to private individuals as e-invoices?
No. The e-invoicing obligation only applies to B2B transactions. Invoices to private individuals (end customers who are not registered as businesses) can continue to be issued as PDF or paper.
I use Toggl or other time tracking tools – can I create XRechnung with them?
Time tracking tools such as Toggl, Clockify, or Harvest generally do not generate XRechnung directly. You must export the time records and process them further in accounting software or our generator. Alternatively, APIs can be used to programmatically convert time data into XRechnung.
As a freelancer you do not need to become an XML expert. Our free XRechnung Generator creates legally compliant e-invoices from your inputs – entirely in the browser, without data sharing, without registration. Validate each invoice with our Viewer before sending.