Ten weeks before 1 January 2027, calls for a delay are getting louder in Germany: the Central Association of German Skilled Crafts (ZDH) wants to push the obligation to issue e-invoices back by a year, and regional chambers of crafts have joined in — most recently, this week, the Saxon crafts council. The law itself has not changed. What is being demanded, what applies and how to plan now.
As of 17 October 2026. The deadlines are set in § 27(38) of the German VAT Act (UStG). We are not aware of any bill that would change them. If that changes, we will update this article.
What the crafts sector is asking for
On 22 June 2026 the ZDH proposed moving the issuing obligation for businesses with more than €800,000 prior-year turnover from 1 January 2027 to 1 January 2028 — under the motto “set the rules first, then start”. Its reasons:
- The standard was not ready. The ZDH called for a B2B-ready version of EN 16931 and a binding mapping of the mandatory VAT details to e-invoice fields. Without them, software vendors interpreted the standard differently.
- Exchange does not yet work smoothly in practice. 1,926 crafts businesses took part in a ZDH survey in early 2026; sending and receiving were “not yet running smoothly”. Cited problems include invoices failing validation, sender and recipient validation tools giving different results, and hybrid invoices whose PDF and data differ.
- More time to test. A one-year delay would give software vendors time for the new standard and businesses a test phase before input VAT risks kick in.
What applies
As long as the law is not amended, it applies as it stands. Under § 27(38) UStG, businesses whose total turnover in the previous year exceeded €800,000 must issue e-invoices for supplies from 1 January 2027; everyone else from 1 January 2028. All businesses have had to be able to receive them since 2025. Details and the trap with December supplies are in Germany’s e-invoicing obligation in 2027.
The latest BMF letter of 15 October 2026 does not touch the deadlines either. It grants a grace period until year-end for the content of e-invoices — not for the obligation itself (Third BMF letter on e-invoicing).
Which arguments have since been addressed
- The new standard is out — as EN 16931-1:2026, published in May 2026. The formats are only now catching up: XRechnung 4.0 exists as a preliminary version (XRechnung 4.0), and there is no date yet for ZUGFeRD. So the 2027 start runs on the previous version of the standard.
- Mandatory details and mapping are covered by the BMF letter of 15 October: all mandatory details belong in the XML, mapped according to the KoSIT and FeRD tables.
- Construction and down payments: at the initiative of the ZDH and the construction federation ZDB, relief has applied since February until 30 June 2030 — totals per trade in the XML, the breakdown in a readable attachment.
- Day-to-day exchange remains open: no letter fixes differing validation results or inconsistent hybrid invoices. That remains a matter for software — and for checking every incoming invoice.
How to plan now
- Plan for 1 January 2027. If you are above €800,000, plan as if there will be no delay. A later law can only bring relief.
- Check the threshold. What counts is total turnover in 2026; below it, in 2027 you may still issue paper invoices or — with the recipient’s consent — PDF invoices.
- Test receiving, not just sending. Check incoming invoices and clear discrepancies with the sender before booking them.
- Issue a first real invoice — a ZUGFeRD invoice in the EN 16931 profile meets the German obligation and can also be read as a PDF.
Frequently asked questions
Is Germany’s e-invoicing obligation being postponed to 2028?
As of 17 October 2026, no. The ZDH and several chambers of crafts are calling for it, but the law (§ 27(38) UStG) still names 1 January 2027 for businesses above €800,000 prior-year turnover.
Who could postpone the deadline?
Only the legislator, by amending the VAT Act. A BMF letter cannot extend deadlines set by statute.
With €750,000 turnover, do I have to issue e-invoices in 2027?
No, if your total turnover in 2026 does not exceed €800,000: then you may still issue other invoices in 2027, but not from 2028. You must already be able to receive e-invoices.
What if my software is not ready by 1 January?
The law makes no exception for that. A stopgap is to create invoices as ZUGFeRD files with a standalone tool until your accounting software is ready.
In short
- The crafts sector wants the issuing obligation moved from 1 January 2027 to 1 January 2028.
- The law is unchanged; no amending bill is known, and the BMF letter of 15 October leaves the deadlines in place.
- Some of the arguments have since been addressed; the day-to-day exchange problems have not.
- Plan for January 2027 — and check incoming invoices.
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E-Rechnung Pro creates and validates documents against EN 16931:2017 — the version ZUGFeRD 2.x and Factur-X are built on today. We are following the EN 16931-1:2026 revision and will support it as the formats adopt it.