E-invoicing mandate 2027: a checklist for businesses
Since 1 January 2025, all businesses in Germany have had to be able to receive e-invoices. From 1 January 2027, companies with prior-year turnover of more than 800,000 euros must issue e-invoices to other domestic businesses, and from 1 January 2028 this applies to everyone. Small businesses under § 19 UStG (German VAT Act, small business scheme) are permanently exempt from the obligation to issue e-invoices, but they too must be able to receive them.
The deadlines of the e-invoicing mandate at a glance
The mandate is based on the Wachstumschancengesetz (Growth Opportunities Act), and the transitional rules are set out in § 27(38) UStG:
| Period | Receiving | Issuing in domestic B2B |
|---|---|---|
| since 1.1.2025 | Mandatory for all businesses | E-invoice or paper invoice; other electronic formats such as PDF with the recipient's consent |
| Supplies in 2027 | Mandatory | E-invoice mandatory if prior-year turnover exceeded 800,000 euros; otherwise paper or, with consent, PDF are still allowed. EDI procedures are permitted until the end of 2027 |
| from 1.1.2028 | Mandatory | E-invoice mandatory for all businesses, with exceptions such as for small businesses and small-amount invoices |
Important with regard to the transitional rules: you only need the recipient's consent for a different electronic format such as PDF. During the transition period, you may send a paper invoice even without consent. You may always issue an e-invoice without consent anyway.
The mandate concerns supplies between businesses established in Germany. Invoices to private customers are not affected. Separate rules have applied for some time to invoices to public contracting authorities, usually in the XRechnung format.
E-invoicing mandate for small businesses
Small businesses within the meaning of § 19 UStG do not have to issue e-invoices. Under § 34a UStDV (German VAT Implementing Ordinance), their invoices may always be transmitted as other invoices, i.e. on paper or, with the recipient's consent, in a different electronic format. In its circular of 15 October 2025, the BMF (Federal Ministry of Finance) confirms that consent does not require any particular form: there merely has to be agreement on the format.
The obligation to receive, on the other hand, also applies to small businesses. If you receive an e-invoice from a supplier, you must be able to accept and store it. According to the BMF, a normal email inbox is sufficient for receiving by email; a separate inbox just for e-invoices is not required.
Since 2025, the small business thresholds have been 25,000 euros in prior-year turnover and 100,000 euros in the current year. If you exceed them, you are subject to standard taxation and therefore, from 2028 at the latest, also to the obligation to issue e-invoices. You can read more about this in the article Who is liable for VAT?.
Another exception concerns small-amount invoices of up to 250 euros and travel tickets. These may also permanently be issued as other invoices (§§ 33, 34 UStDV).
What is an e-invoice?
Under § 14(1) UStG, an e-invoice is an invoice in a structured electronic format that enables electronic processing and complies with the European standard EN 16931. A normal PDF is not an e-invoice, even if it arrives by email.
The two common formats in Germany:
- XRechnung is a pure XML data record without a visible document. It is the standard for public contracting authorities and is also used in B2B.
- ZUGFeRD is a hybrid format: a PDF/A-3 with embedded XML data. People read the PDF, software processes the data. ZUGFeRD only counts as an e-invoice in profiles that carry the complete invoice content in accordance with EN 16931. Reduced profiles such as MINIMUM or BASIC WL are not sufficient.
You can find an overview of terms and obligations on our page on e-invoicing.
Checklist: how small businesses can prepare
1. Clarify whether you are affected
- Are you a small business under § 19 UStG? Then you only need to receive.
- Was your total turnover in 2026 above 800,000 euros? Then the obligation to issue applies to supplies from 1 January 2027.
- If you are below that, you have until the end of 2027; the obligation applies from 2028 at the latest.
- Which of your customers are domestic businesses, and which are private customers or public authorities?
2. Make sure you can receive
- Decide which email address suppliers should send e-invoices to, and let them know.
- Make sure you can display XML files in a readable form and check them. An XML attachment is hard to read without suitable software.
3. Adapt your archiving
- Keep the XML file as the original. The PDF visual representation alone is not enough.
- Invoices must be kept for eight years. Read the details in the article on GoBD and archiving.
4. Choose software for sending
- Check whether your invoicing program can generate XRechnung and ZUGFeRD in accordance with EN 16931.
- Look for validation before sending so that your invoice is not rejected by the recipient.
- Decide whether you want to send invoices by email or via the Peppol network.
5. Maintain master data
- Complete customer data with address and, where necessary, VAT ID.
- For public authorities: Leitweg-ID. For large customers: purchase order numbers or other references the customer requires.
- Clear item descriptions, units of measure and tax rates.
6. Do a test run
- Send your first e-invoices to individual customers before the mandate takes effect.
- Ask whether receipt and processing work.
- Clarify with your tax adviser how e-invoices get into your accounting.
A realistic look at benefits and effort
Structured invoice data can be processed further without manual retyping. This saves time, especially when receiving, and reduces typing errors. Invoices reach the recipient immediately, and there are no postage or printing costs.
This is offset by a one-off effort: choosing software, checking master data, adapting processes. If you start early, you can do this without time pressure and use the transition period for tests with individual customers.
E-invoices with faktoora
With faktoora, you create e-invoices as XRechnung, ZUGFeRD or Factur-X in accordance with EN 16931. Every invoice is validated before sending, including a validation report, and is sent to the recipient by email or via the Peppol network. You also receive and check incoming e-invoices in faktoora.
Note: This article is for general information purposes and does not replace tax or legal advice.
Sources
- § 27(38) UStG: transitional rule on e-invoicing, gesetze-im-internet.de
- § 14 UStG: issuing invoices, gesetze-im-internet.de
- § 34a UStDV: invoices from small businesses, gesetze-im-internet.de
- BMF circular of 15 October 2025 on the introduction of mandatory e-invoicing, Bundesministerium der Finanzen
Frequently asked questions
Does the e-invoicing mandate apply to small businesses?
Not for issuing: small businesses may continue to send paper invoices or, with the recipient's consent, PDF invoices. They have had to be able to receive e-invoices since 1 January 2025.
What changes in 2027?
For supplies from 1 January 2027, companies with total turnover of more than 800,000 euros in the previous year must issue e-invoices to domestic businesses. Smaller companies may continue to use other invoices until the end of 2027.
Do I need the customer's consent for a paper invoice?
No. During the transition period, a paper invoice is permitted without consent. The recipient only has to consent to other electronic formats such as PDF.
Is a PDF invoice an e-invoice?
No. An e-invoice requires structured data in accordance with EN 16931. ZUGFeRD is a PDF with embedded XML data and counts as an e-invoice in the appropriate profiles.
Is an email inbox enough for receiving?
Yes. According to the BMF, a normal email inbox is sufficient; a separate inbox just for e-invoices is not necessary.