Rights & obligations

E-invoicing from 2027: who has to switch now – and who still has a year

In Germany the first transition period ends on 31.12.2026. From 2027, companies with more than €800.000 turnover in the previous year must send e-invoices. Plain English.

From the E-Invoicing Monster

5 min read

E-Invoicing Monster says: “A PDF is not an e-invoice.”

Are you still sending your invoices as PDFs by email? Then it's worth checking the calendar. No reason to panic, though.

In Germany, electronic invoicing between businesses is becoming mandatory step by step. You've probably already taken the first step: since 1 January 2025, every domestic business has to be able to receive e-invoices. Now the next stage is coming – and this one is about sending them.

In short

  • Since 2025, every business in Germany has to be able to receive e-invoices.
  • From 1 January 2027, companies with more than €800.000 in turnover in 2026 must send e-invoices.
  • From 2028, this applies to all invoices between businesses in Germany.
  • A normal PDF is not an e-invoice.

What an e-invoice actually is

An e-invoice is not a PDF file. That's the most common misconception. It means an invoice in a structured data format that a computer can read without retyping – according to the European standard EN 16931. In Germany, these are mainly the XRechnung (a pure file for machines) and ZUGFeRD from version 2.0.1 (a PDF for viewing, with embedded data for reading out). A normal PDF invoice legally counts as an “other invoice”.

The deadlines at a glance

E-invoicing in Germany: the stages
  1. 1 January 2025All businesses must be able to receive e-invoices. An email inbox is enough for that.
  2. until 31 December 2026We are herePaper and PDF invoices are still allowed, PDF only with the recipient's consent.
  3. from 1 January 2027Anyone whose total turnover in 2026 was more than €800.000 must issue e-invoices. Everyone else may continue invoicing as before for one more year. EDI procedures remain permitted in 2027.
  4. from 1 January 2028E-invoices for all sales between businesses in Germany – regardless of turnover.

Applies to invoices between businesses in Germany. Legal basis: § 27 para. 38 UStG (German VAT Act).

What counts for 2027 is your total turnover in 2026. If it's over 800.000 euros, you'll send e-invoices to other businesses in Germany from 1 January 2027. If it's below that, you have until the end of 2027. That's what the German VAT Act (Umsatzsteuergesetz) says.

Who isn't affected

  • Invoices to private individuals: The obligation only applies between businesses in Germany.
  • Small-amount invoices up to 250 euros gross, and travel tickets.
  • Small businesses as defined in § 19 UStG (the German VAT Act) don't have to issue e-invoices. But they too must be able to receive them.

For clubs, practices and law firms: what matters is whether you act as a business for VAT purposes. If in doubt, your tax adviser can clarify that in five minutes.

New in October 2026: the third BMF letter

In a third letter dated 15 October 2026, Germany's Federal Ministry of Finance answered further practical questions. The deadlines stay as they are. A few points that help in everyday business:

  • A technical error that doesn't affect any mandatory detail doesn't automatically cost you the input tax deduction. What matters is that the mandatory details are correct and complete.
  • For final invoices after instalment payments, a simplification applies until 30 June 2030.
  • For construction work, it's enough to state the trades and totals in the structured part if the detailed bill of quantities is attached in readable form.

If you want to know the details, you'll find the sources below. For your individual case, your tax adviser is the right person to ask.

Keep calm

The obligation isn't rocket science. Many invoicing programs have long been able to create e-invoices. Often it's just a matter of one setting, clean master data and a test run with a customer.

How to switch over calmly

The switch is usually smaller than it sounds. Three starting points are typical:

  • Your invoicing software can already do it. Then it's about settings, master data and a test run.
  • Your software can't do it. Then it's worth switching or adding something. The important thing is that nobody types anything twice.
  • You write invoices in Word or Excel. Now at the latest is a good time for proper software – even if you don't have to until 2028.

Also think about incoming invoices. E-invoices often arrive in the inbox as an XML file that nobody can read without the right software. A tool that displays these files and passes them on to accounting saves a lot of hassle. And the e-invoice is stored in its original form – a printout isn't enough.

First check the software, then ask a customer, then switch over. In that order, things rarely get hectic.

The E-Invoicing Monster

Three questions we hear a lot

“Do I have to ask my customers whether they want e-invoices?” No. Since 2025, you no longer need the recipient's consent for an e-invoice – every business in Germany must be able to accept them. You only need consent as long as you want to send a PDF instead.

“What about customers abroad?” The obligation applies to sales between businesses in Germany. Invoices to companies in other countries continue to follow the previous rules, and some countries have their own requirements. If you deliver a lot abroad, have that checked separately once.

“Is it enough for e-invoices to land in a mailbox?” For receiving them, yes. For working with them, not really: an XML file is hard to read, and invoices must be stored unaltered and retrievable. A dedicated mailbox just for invoices plus a program that displays and forwards them is the most relaxed solution.

What you can do now

  • Check your total turnover for 2026: above or below 800.000 euros?
  • Ask your software provider whether your program can output XRechnung or ZUGFeRD from version 2.0.1.
  • Decide which address e-invoices should arrive at, and tell your suppliers.
  • Do a trial run with a regular customer before it becomes mandatory.
  • Clarify special cases such as progress invoices or invoices for construction work with your tax adviser.

You want to write invoices, not think about data formats? The E-Invoicing Monster looks at your workflow and connects invoicing software, mailbox and accounting. If programs need to talk to each other, the Connect Monster joins in. Price upfront, as always.

Sources

  1. § 27 Abs. 38 UStG – Übergangsregelung zur E-Rechnung (gesetze-im-internet.de)
  2. IHK Region Stuttgart: E-Rechnungen – Übergangsfristen und Ausnahmen (Stand 15.10.2026)
  3. IHK Ostthüringen: Nächste Stufe der E-Rechnung (Stand 28.10.2026)
  4. Ebner Stolz: Drittes BMF-Schreiben zur E-Rechnung – weitere Praxisfragen geklärt (26.10.2026)
  5. IHK Hannover: E-Rechnung – BMF veröffentlicht weitere Klarstellungen

Sources last checked on 05.11.2026. The links lead to external pages.

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