Germany's e-invoicing mandate from 2027: who has to switch now

In eleven weeks, the second stage of the e-invoicing mandate in Germany begins. Since January 2025, every domestic business has had to be able to receive e-invoices. From 1 January 2027, the first businesses must also issue them: everyone whose total turnover (Gesamtumsatz) in 2026 is above €800,000. This article explains who is affected, what remains allowed until the end of 2027 and what should be done before the turn of the year.

Who has to issue e-invoices from 2027

The mandate applies to invoices between businesses that are both established in Germany. It does not cover invoices to consumers, small-amount invoices up to €250 gross, or travel tickets. Small businesses under § 19 UStG (Kleinunternehmer) are permanently exempt from issuing e-invoices — but they still have to receive them. More on this in VAT in e-invoices.

Reading the €800,000 threshold correctly

The threshold decides whether you have to switch in eleven weeks or in fourteen months. It is misread more often than you might think:

• The previous year is what counts. For 2027, it is the turnover of calendar year 2026 — not the current one, and not an average.
• It means total turnover as defined in § 19 Abs. 2 UStG. That is all taxable turnover excluding VAT, including sales to consumers. If half of your sales go to end customers, you can be above the threshold even though your B2B business is small. Certain tax-exempt sales and sales of fixed assets are left out.
• “Above €800,000” means above. If you reach exactly €800,000, you still fall under the transitional rule.
• Organschaft (VAT group): According to the BMF letter of 15 October 2024, the turnover of the entire group counts here. Without an Organschaft, each company checks for itself — so one sister company may have to switch a year earlier than the other.

The practical problem: you will only know your 2026 turnover for certain after 31 December — but the mandate applies from 1 January. If you are at €700,000 in the autumn and expect a strong final quarter, prepare as if you were already above the threshold. The other way round, switching early costs nothing: e-invoices are allowed for everyone in 2027 as well.

What remains allowed until the end of 2027

§ 27 Abs. 38 UStG provides two exceptions for 2027. Both expire on 31 December 2027:

1. Turnover in 2026 not above €800,000: For supplies made in 2027, you may continue to send paper invoices or — if the recipient agrees — use another electronic format, such as a plain PDF.
2. EDI, regardless of size: If you currently invoice through an EDI procedure under Recommendation 94/820/EC, you may continue to do so for supplies made in 2027, again with the recipient's consent.

What matters here is the date of supply, not the invoice date. The relief for 2026 covers supplies made in 2026, but only invoices sent by 31 December 2026. So if you are above the threshold and bill a December supply in January 2027, that invoice already has to be an e-invoice. For year-end invoices and advance payments, this is where people trip up first.

Which format counts as an e-invoice

An e-invoice is an invoice in a structured format compliant with EN 16931 that is sent and received electronically. A PDF that is only an image of the invoice does not count — no matter how it was created. The recognised formats are:

• XRechnung — pure XML, the German format from public procurement;
• ZUGFeRD from version 2.0.1 — a PDF/A-3 with embedded XML, readable by people and machines at the same time. The MINIMUM and BASIC WL profiles are excluded: they lack mandatory information and do not count as e-invoices. Which profile is enough for what is explained under profiles.

The BMF letter of 15 October 2025 clarified two points that matter a great deal in practice. First: in a hybrid format such as ZUGFeRD, the XML part is what counts. If the visible PDF page differs from it, the recipient's input VAT deduction is at risk. Second: all mandatory information must be in the XML itself; a reference to an attachment is not enough. How XRechnung and ZUGFeRD differ otherwise is shown in XRechnung or ZUGFeRD.

The law does not prescribe a transmission channel. An email with the file attached is enough.

Roadmap to 31 December

Eleven weeks are enough, as long as you don't spend them choosing software. A sensible order:

1. Project your 2026 turnover. If you are safely below the threshold, you have one more year — use it anyway, the mandate arrives in 2028.
2. Ask your invoicing software what it produces. Not “can it do e-invoices?”, but: which format, which version, which profile. ZUGFeRD MINIMUM from older software is not an e-invoice.
3. Create a real invoice and have it checked. Not a sample from the vendor, but your own, with your master data. A validator shows within seconds whether the file meets the standard — and which rule it fails.
4. Clean up your master data. VAT ID (USt-IdNr.) or tax number, complete addresses, date or period of supply, payment terms. Anything that used to be free text in the footer now has to go into fields.
5. Inform your customers. Ask for the address e-invoices should go to and, for public authorities, the Leitweg-ID (routing ID).
6. Sort out retention. The structured part is what you archive, unchanged, for eight years — see Retaining e-invoices and the GoBD.

If you still write invoices in Word or Excel today, you don't have to replace your whole setup right away. An existing PDF invoice can be converted into a ZUGFeRD file — on condition that someone confirms the extracted data. The guide Convert a PDF invoice to ZUGFeRD shows how.

What changes for invoice recipients

Even if you only have to issue e-invoices from 2028, you will receive more of them from January: from all suppliers above the threshold. This is not a new obligation — you have had to receive them since 2025 — but only now does it become visible in day-to-day work. A mailbox is enough; what matters is that someone imports the file or at least checks it, instead of just looking at the PDF page. The XML part is the invoice. Tips for incoming invoices are in the guide How to check an e-invoice, and for passing them on to bookkeeping in Handing e-invoices to your accountant.

Frequently asked questions

My 2026 turnover is just above €800,000 — can I still send a PDF in January?

No. For supplies from 1 January 2027, you will then need an e-invoice, unless you already invoice through an EDI procedure. Your customer's consent changes nothing: the exception with consent only applies to businesses up to €800,000.

Does the threshold apply per customer or per invoice?

Neither. What counts is the total turnover of the issuing business in the previous year — across all customers, B2B and B2C combined.

I am a Kleinunternehmer. Do I have to do anything in 2027 or 2028?

You don't have to issue e-invoices; this exemption has no end date. But you have had to receive them since 2025 — an email address where invoices arrive is enough for that.

Is a PDF that my software calls an “e-invoice” enough?

Only if it contains an XML compliant with EN 16931 and the profile is not MINIMUM or BASIC WL. The quickest way to find out is to run the file through a validator: it shows the format, the profile and every rule that is violated.

What happens if I keep sending paper from January?

Then the invoice is not a proper invoice within the meaning of the German VAT Act. The risk lies mainly with your customer, whose input VAT deduction depends on a proper invoice — and that is why customers above the threshold will ask for e-invoices themselves.

Summary

• From 1 January 2027, everyone with total turnover above €800,000 in 2026 issues B2B invoices as e-invoices; from 2028, everyone else does too.
• What counts is total turnover excluding VAT, including sales to consumers; for an Organschaft, the turnover of the whole group.
• Until the end of 2027, paper and PDF with consent (only up to €800,000) and EDI (for everyone) remain allowed.
• The date of supply is what counts; December supplies billed in January already fall under the mandate if you are above the threshold.
• XRechnung and ZUGFeRD from 2.0.1 count as e-invoices — except MINIMUM and BASIC WL. In a hybrid format, the XML is what counts.

Start by checking what your software produces today: upload an invoice to the free validator — no sign-up needed. And if it fails: in E-Rechnung Pro you can create ZUGFeRD invoices in the EN 16931 profile or convert existing PDFs, free during the beta until 31 December 2026.