German e-invoice mandate 2027: who must issue e-invoices from 1 January 2027?

In short: from 1 January 2027, businesses whose total turnover in the previous year (2026) was more than €800,000 must issue e-invoices for supplies to other domestic businesses: XRechnung or ZUGFeRD, no longer a plain PDF. Everyone else follows on 1 January 2028 ^[1][2]. Every business established in Germany has had to be able to receive e-invoices since 1 January 2025 ^[1]. The checker further down this page tells you which date applies to you.

Does it apply to me? The common cases

• 2026 total turnover above €800,000: for supplies from 1 January 2027 to other domestic businesses you need an e-invoice ^[1][2].
• 2026 total turnover of €800,000 or less: for supplies in 2027 you may still issue paper invoices or, if the customer agrees, PDF invoices. Your duty starts on 1 January 2028 ^[1][2].
• Small businesses (Kleinunternehmer), consumers, invoices up to €250: there are exceptions (see below). You must still receive e-invoices, small businesses included ^[4].

The timeline: 2025, 2027, 2028

<iframe src="https://einvoicemap.com/embed/countdown/de/en/" title="Next e-invoicing date: Germany" width="320" height="180" loading="lazy" style="border:0"></iframe>
<p><a href="https://einvoicemap.com/en/de/e-invoicing-mandate-2027-2028/">E-invoicing deadlines (Germany): E-Invoice Map</a></p>

Careful at the turn of the year: the law ties the transition until the end of 2026 to supplies made before 1 January 2027 and to invoices sent by 31 December 2026 ^[2]. The text does not clearly say whether an invoice issued in January 2027 for work done in December 2026 can still be a paper or PDF invoice. To be safe, issue such invoices by 31 December 2026 or send them as e-invoices right away. This is our reading of the wording, not a statement by the BMF.

Which turnover counts for the €800,000 threshold?

What counts is the issuer's total turnover in the previous calendar year ^[2]. For invoices in 2027 that is your 2026 total turnover, not your customer's turnover and not the amount of a single invoice. The threshold is €800,000, and exactly €800,000 is still below it: the law says "not more than 800 000 euro" ^[2].

Total turnover here means the Gesamtumsatz under section 19(2) UStG: the sum of taxable supplies (section 1(1) no. 1 UStG) calculated on the basis of payments received, minus certain supplies; sales of fixed assets are left out ^[2][6]. So what counts is what you actually received in 2026, not what you invoiced in 2026. Check borderline cases, such as a business started in 2026, with your tax adviser.

What changes on 1 January 2027, and what only in 2028?

• 2027: whoever was above the threshold in 2026 must issue e-invoices. Everyone else may keep using the old routes (paper, PDF with consent) but must be able to receive ^[1][2].
• 2028: the transition for issuers up to €800,000 ends. From then on an e-invoice is the rule for everyone, unless an exemption applies. The EDI transition also ends after 2027 ^[1][2].
• Earlier, voluntarily: the transition rules are a right of the issuer, not a duty. Anyone may send e-invoices sooner. And because the choice lies with the issuer, a customer can pick a supplier who already issues e-invoices ^[1].

The transition rules in detail

During the transition periods these routes apply ^[1][2][4]:

• Paper invoice: always allowed.
• PDF or another electronic format (for example an email with a PDF): only with the customer's consent. The consent needs no special form and can be tacit, for example by accepting the invoice without objection, or through general terms and conditions ^[4].
• EDI procedures (for example EDIFACT) that do not follow EN 16931: with the customer's consent until the end of 2027 ^[2].

After that only an e-invoice counts. The parties choose the format themselves; any format that follows the European standard EN 16931 is permitted ^[4].

Who is covered, and who is not?

The mandate applies to invoices between domestic businesses: supplier and customer both have their seat, management or a fixed establishment involved in the supply in Germany ^[1]. If one of them is not established in Germany there is no duty to issue an e-invoice ^[4] (more: Do foreign suppliers have to e-invoice?). Businesses include freelancers, landlords, doctors and small businesses ^[1][4].

You do not have to issue an e-invoice (an "other invoice" is enough) ^[1][4]:

• for invoices to consumers (B2C),
• for small-amount invoices whose total does not exceed €250 (section 33 UStDV) ^[7],
• for tickets issued for the carriage of passengers (section 34 UStDV) ^[8],
• as a small business (Kleinunternehmer) under section 19 UStG (section 34a UStDV; receiving is still mandatory, see e-invoices for small businesses) ^[9],
• for many VAT-exempt supplies under section 4 nos. 8 to 29 UStG (for example residential letting, medical treatment) ^[4],
• for supplies to legal entities that are not businesses (for example many associations) ^[4].

In these cases you may still choose to issue an e-invoice. Between domestic businesses that needs no consent for small amounts, tickets and small-business invoices ^[4]. Invoices to public authorities (B2G) additionally follow their own rules, such as the federal e-invoicing ordinance; where both apply, the stricter one prevails ^[5].

What does "structured" mean? What counts as an e-invoice

An e-invoice is an invoice issued, transmitted and received in a structured electronic format that allows electronic processing ^[3]. The format must follow the European standard for electronic invoicing (EN 16931); alternatively issuer and customer can agree a format that converts losslessly into that standard ^[3][4]. In Germany that mainly means:

• XRechnung: a pure XML file, the German standard ^[4].
• ZUGFeRD from version 2.0.1, except the MINIMUM and BASIC-WL profiles: a PDF with an embedded XML file ^[4]. The XML part is what counts.
• Other formats following EN 16931 (for example Factur-X) are also permitted ^[4].

A plain PDF, a scan or a Word document is not an e-invoice, even if it arrives by email. German law calls it an "other invoice" (sonstige Rechnung) ^[3]. The same goes for a file with format errors: if it does not follow a permitted syntax it only counts as an other invoice ^[4]. More on the formats: XRechnung or ZUGFeRD?

What happens if you get it wrong?

Where an e-invoice is required and an other invoice is issued instead, that invoice is not a proper invoice, so in principle it does not entitle the customer to deduct input VAT ^[4]. If the other invoice is correct and complete in content, the conditions for input VAT deduction under section 15.2a(1a) of the VAT Application Decree (UStAE) will regularly still be met; otherwise it must be corrected with an e-invoice ^[4]. For your customers a correct e-invoice is therefore worth real money. According to the BMF letter of 15 October 2026, issuing an other invoice instead of an e-invoice is not an administrative offence under section 26a(2) no. 1 UStG ^[5]. Business-rule errors that do not concern a mandatory VAT field, such as a missing "Buyer reference", do not matter for VAT ^[4][5].

New since 15 October 2026: supplementary BMF letter

On 15 October 2026 the BMF issued another letter supplementing those of 15 October 2024 and 15 October 2025 ^[5]. It does not move any deadline, but it contains reliefs that matter for 2027:

• Down-payment, advance and instalment invoices issued before your own start date need not be e-invoices, even if the supply and payment come later ^[5].
• Final invoices: until 30 June 2030 it is not objected to if amounts already paid are deducted as a sum in field BT-113 ("Paid amount") with the details in field BT-22 ("Invoice note") ^[5].
• Construction work: for now it is enough to list the trades with their totals in the structured part if a detailed breakdown is attached as an embedded document ^[5]. More: E-invoices in the trades.
• Gross-price invoices under EN 16931 issued by 31 December 2027: totals per tax rate are enough if the individual items are in an embedded attachment ^[5].
• Mass-market business: an issuer who could not know the customer was a business is not objected to. For ongoing contracts it is enough to clarify this when the contract starts ^[5].

Will it be postponed?

The steps come from the Growth Opportunities Act ^[10] and sit in section 27(38) UStG ^[2]. The text of the law still names 1 January 2027 and 1 January 2028 ^[2]. As of 23 October 2026 no postponement has been decided. The BMF last updated its FAQ in March 2026 ^[1]; its most recent letter, of 15 October 2026, keeps the deadlines ^[5]. So plan for 1 January 2027.

Checklist for 1 January 2027

1. Check your 2026 turnover: is your total turnover (section 19(2) UStG) above €800,000? Then the duty applies to you from 1 January 2027. The checker on this page helps you classify yourself.
2. Prepare to issue: can your invoicing software produce XRechnung or ZUGFeRD 2.0.1 or later (not MINIMUM/BASIC-WL)? Compare tools in the software comparison or start with free options.
3. Make sure you can receive: set an email address for invoices and open an XRechnung in our free viewer; the file never leaves your browser. You must keep the XML part unchanged for eight years; details in receiving e-invoices.
4. Clarify with customers: to which address or through which route should your e-invoices go? Whether a customer is reachable over Peppol is shown by the Peppol ID lookup; in Germany Peppol is only one route among several, see Will my e-invoice arrive?.
5. Test the format: create a test invoice and check it with a validator or the viewer before the first real one goes out ^[4].
6. Put the deadline in your calendar: subscribe to the 1 January 2027 (and 2028) dates as a calendar file.

FAQ

When does the e-invoicing mandate start in 2027? For supplies from 1 January 2027, if your total turnover in the previous year (2026) was more than €800,000. For everyone else it starts on 1 January 2028 ^[1][2].

Which turnover counts for the €800,000 threshold? The issuer's total turnover in the previous year under section 19(2) UStG, calculated on payments received, without sales of fixed assets ^[2][6].

What applies if my 2026 turnover was below €800,000? Then in 2027 you may still issue paper invoices or, with the customer's consent, PDF invoices. From 1 January 2028 you need e-invoices. You must already be able to receive them ^[1][2].

Is a PDF by email still enough from 2027? Only during the transition period and only with the customer's consent. If you must issue e-invoices in 2027 you need XRechnung or ZUGFeRD; a PDF without embedded XML is not an e-invoice ^[1][3][4].

Do small businesses have to issue e-invoices from 2027? No. Their invoices may always be issued as other invoices ^[4][9]. They must still be able to receive e-invoices ^[4].

Does the mandate apply to invoices up to €250? No. Small-amount invoices with a total of up to €250 and tickets are exempt ^[4][7][8].

Which ZUGFeRD version is allowed? ZUGFeRD from version 2.0.1, except the MINIMUM and BASIC-WL profiles ^[4].

How do I open an XRechnung or ZUGFeRD file? With a viewer that displays the XML data. Our free viewer works in your browser without uploading the file.

Will the mandate be postponed to 2028? Not under the current law: section 27(38) UStG still names 1 January 2027 ^[2]. As of 23 October 2026 no change has been decided.

Not legal or tax advice. Every fact is sourced and was checked on 23 October 2026. The German version of this page and the official German texts prevail.