Germany’s e-invoicing mandate: what actually affects holiday lets — and what does not
Most guest invoices are B2C and fall outside the e-invoicing mandate entirely. Three cases do fall inside it, and one of them is routinely overlooked.
Few topics generate as much vague unease among hosts as Germany’s e-invoicing mandate. The good news first: for most of what you issue day to day, it does not apply. The bad news: there are exceptions, and one of them is missed by exactly the businesses that write the most invoices.
The framework in three sentences
The German e-invoicing mandate covers domestic B2B transactions only — invoices between two businesses established in Germany. An e-invoice in the legal sense is not a PDF but a structured data set conforming to EN 16931; in practice XRechnung (pure XML) or ZUGFeRD (a hybrid of PDF/A-3 with embedded XML). A PDF sent by email is explicitly not an e-invoice.
What already applies: being able to receive
The part that gets overlooked because it sounds unremarkable: since 1 January 2025, every domestic business must be able to receive e-invoices. Without exception — that includes small businesses under § 19 UStG.
Technically an email inbox is enough. What is usually missing is not the technology but the process: a fixed address suppliers send to, and someone who files the documents rather than leaving them in an inbox. A ZUGFeRD file looks like a PDF but legally is the XML inside it — printing the visible part and filing that means the original was never archived.
What comes when: having to issue
On the issuing side, transitional rules apply:
- 2025 and 2026: paper invoices remain permitted. PDFs and other unstructured formats require the recipient’s consent.
- From 1 January 2027: anyone with more than €800,000 total turnover in the previous year must issue domestic B2B invoices as e-invoices. Smaller issuers can, under certain conditions, use the transitional period until the end of 2027.
- From 1 January 2028: the issuing obligation applies to everyone.
Small businesses under § 19 UStG are generally exempt from issuing e-invoices for their own supplies. They are not exempt from having to receive them.
Now the holiday-let part
Your guest invoices are usually B2C. A family booking a week on the coast is not a business, so those invoices fall outside the mandate. That is precisely why the alarm among pure holiday-let hosts is largely unfounded.
Three cases do fall inside it:
1. Corporate bookings. Contractor accommodation, business travel, a company booking for employees and wanting the invoice made out to the firm: that is B2B. Anyone letting regularly to companies is directly affected by the 2027/2028 dates.
2. Invoices from and to service providers. Cleaning, maintenance, photography, agency commission — all B2B. Here it is mainly the receiving side that affects you, and it does so already.
3. Owner settlements. This is the one that gets missed. If you let properties on behalf of others and settle up with the owners, you have a relationship between two businesses in front of you — depending on the arrangement, with invoices in both directions. For an agency with thirty owners and monthly settlements, this is not an edge case; it is the highest-volume invoice stream in the business.
Whether and in which direction settlement happens in your specific arrangement — a commission invoice to the owner, a self-billing procedure, intermediation in another’s name — determines what has to run as an e-invoice from 2027. That question belongs with your tax adviser, and before 2027 rather than the December preceding it.
What makes sense now
- Secure the receiving side: one fixed invoicing address, a defined filing location, archive the XML original rather than a printout.
- Work out what share of your outgoing invoices is B2B. For pure guest letting, often close to zero; for management with owners, quickly the majority.
- Have owner settlements classified — both for tax and in form.
- Check your prior-year turnover against the €800,000 threshold so you know whether 2027 or 2028 is your date.
Reynt today produces invoices as PDFs with correct EU VAT, city tax, and credit notes when a booking changes — and already carries the fields the formats require, such as tax exemption codes. Structured output as XRechnung or ZUGFeRD does not exist yet; it is planned, not built. We would rather write that down than let you discover it in 2027.
This article is an orientation, not tax advice. Which deadlines and duties apply to your business depends on turnover, legal form, and contractual arrangements — that belongs with your tax adviser.
