E-invoicing from 2027: Who must act – and who still has time

The next stage of Germany’s e-invoicing mandate is approaching: from 1 January 2027, many businesses will have to issue invoices to other German businesses as e-invoices. This is often shortened to “everyone needs e-invoices from 2027”. That is not quite right.

The issuer’s turnover, the type of transaction and several statutory exemptions all matter. Businesses that classify their invoices correctly now can avoid a rushed software change or duplicate data entry at the end of the year.

The three dates that matter

• Since 1 January 2025: German businesses must be able to receive e-invoices. In principle, an email inbox is sufficient for receipt.
• From 1 January 2027: The transition period ends for invoice issuers whose previous-year turnover exceeds €800,000. Their domestic B2B transactions generally have to be invoiced electronically.
• From 1 January 2028: Businesses with previous-year turnover of €800,000 or less can no longer use the general transition rule either.

The €800,000 threshold refers to the invoice issuer’s total turnover in the previous calendar year. It is not the value of an individual invoice and not the customer’s turnover.

What is an e-invoice?

An e-invoice is not simply an invoice received by email. It contains invoice data in a structured electronic format that software can process automatically. The key standard is the European EN 16931 standard.

Two formats are particularly common in Germany:

• XRechnung: a pure XML file. It is easy for software to process but requires a viewer to be comfortably read by people.
• ZUGFeRD/Factur-X: a readable PDF with structured XML data embedded in it.

An ordinary PDF without structured invoice data is only an “other invoice”, even when it is sent digitally.

Who the 2027 mandate actually affects

The next stage is particularly relevant to businesses that

1. generate more than €800,000 in turnover in 2026,
2. invoice another German business for a transaction in 2027, and
3. are required to issue an invoice for VAT purposes.

If these conditions are met and no exemption applies, the invoice must be issued as an e-invoice from 2027. A paper invoice or simple PDF is no longer sufficient.

Smaller issuers with previous-year turnover of no more than €800,000 may still use paper in 2027 or, with the recipient’s consent, a simple PDF. This transition ends no later than 1 January 2028.

The exemptions that matter in everyday business

Not every invoice automatically becomes an e-invoice. Key exemptions include:

• invoices to private consumers (B2C)
• low-value invoices of up to €250 gross
• tickets that qualify as invoices
• certain VAT-exempt transactions
• supplies made by small businesses applying the German Kleinunternehmer scheme under section 19 UStG

The last point is frequently missed: under current law, small businesses using the Kleinunternehmer scheme do not have to issue e-invoices themselves. They must nevertheless be able to receive incoming e-invoices. If they move to standard VAT accounting, the issuing requirement may become relevant as well.

For businesses with a point of sale, an ordinary receipt issued to a guest does not suddenly become an XRechnung because of the B2B mandate. But if the business issues a proper invoice of more than €250 to a corporate customer, that specific case needs to be assessed.

Receiving means more than finding an XML attachment

An email inbox may meet the basic legal requirement for receiving an e-invoice. In practice, however, your process should answer four questions:

1. Who identifies an incoming XML file as an invoice?
2. How is it rendered for a person to review?
3. How does its data reach your bookkeeping system or tax adviser?
4. Where is the original structured part retained without alteration?

For German VAT purposes, invoices must be retained for eight years. For an e-invoice, at least the structured part must remain intact in its original form. Printing or saving only the visible PDF is therefore not a complete process.

Your preparation checklist for 2027

Do not wait until December. This short review will show you where you stand:

1. Estimate previous-year turnover: Will your total turnover for 2026 exceed €800,000?
2. Separate invoice types: Which invoices go to businesses and which to consumers?
3. Mark exemptions: Do low-value invoices, exempt transactions or the Kleinunternehmer scheme apply?
4. Complete master data: Addresses, tax details, payment information and contact details must be complete for a valid e-invoice.
5. Generate a test invoice: Open and validate the XML or ZUGFeRD file with a suitable viewer instead of checking only the PDF image.
6. Test receipt and storage: Send a sample e-invoice through the actual inbox, review and retention process you intend to use.

dikas Faktura creates the format automatically

With dikas Faktura, you write an invoice in the usual way. The system generates a PDF and structured e-invoice data compliant with EN 16931 as ZUGFeRD/XRechnung, without entering line items twice. The XML can also be downloaded separately when a customer uses an invoice portal.

Incoming e-invoices can be uploaded and read as source documents. This keeps XML data from becoming an opaque email attachment and puts it into a traceable document workflow. E-invoicing is included even in the free plan.

Try dikas Faktura free of charge or read our checklist for switching POS systems.

Sources

• German Federal Ministry of Finance: e-invoicing questions and answers (German)
• German VAT Act, section 14 – issuing invoices (German)
• German VAT Act, section 27 – transition rules (German)
• ELSTER: German tax administration’s e-invoice viewer

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Last updated: 4 September 2026. This article provides general guidance and is not tax or legal advice. Discuss uncertain cases with your tax adviser.