From 1 January 2027, every German business whose total turnover in 2026 was more than €800,000 has to send e-invoices to its domestic business customers (§ 27(38) UStG). Everyone below that threshold gets one more year, and from 2028 the mandate covers all businesses. Invoices up to €250, tickets and invoices from small businesses stay exempt for good. A PDF sent by email is not an e-invoice, in 2027 or ever.
The receiving side has applied since January 2025; how to meet it without a new subscription is covered in the post on receiving e-invoices. This one is about the other direction: sending.
Who falls under the 2027 sending obligation?
What counts is total turnover (Gesamtumsatz under § 19(2) UStG) in the previous calendar year. For invoices issued in 2027, that year is 2026, which is the year you’re in right now. The law is written as an exception: paper or another format stays allowed in 2027 only if prior-year turnover was “not more than €800,000”. So the obligation starts above €800,000, not at exactly that amount.
If you’re close to the line, you won’t know your 2026 figure until the year is closed. I wouldn’t wait for the accounts in that case. Plan as if you’re over it; the switch costs the same, just without a January deadline breathing down your neck.
| Period | What applies when sending |
|---|---|
| since 1 Jan 2025 | All domestic businesses must be able to receive e-invoices. |
| until 31 Dec 2026 | Everyone may still send paper, or other electronic formats with the recipient’s consent. |
| 2027, prior-year turnover above €800,000 | E-invoices are mandatory. |
| 2027, prior-year turnover up to €800,000 | Paper or other formats remain allowed until 31 Dec 2027. |
| 2027, EDI | EDI invoices outside the EN 16931 format remain allowed with the recipient’s consent until 31 Dec 2027, regardless of turnover. |
| from 1 Jan 2028 | Mandatory for everyone; the permanent exemptions remain. |
What counts as an e-invoice?
An e-invoice is an invoice in a structured electronic format that follows the European standard EN 16931 (§ 14(1) UStG). In Germany that means XRechnung or ZUGFeRD in practice. According to the Federal Ministry of Finance, ZUGFeRD qualifies from version 2.0.1, except for the MINIMUM and BASIC-WL profiles. A plain PDF has no structured format, so it’s out.
The profile is where people trip. Ticking “ZUGFeRD” in your invoicing software doesn’t guarantee the right profile goes out. And a file with format errors isn’t an e-invoice either: under the ministry’s guidance letter of 15 October 2025 (para. 6a) it counts as an ordinary invoice. That letter amends the first guidance letter of 15 October 2024 (BStBl I p. 1320) rather than replacing it.
Which exemptions are permanent?
Three kinds of invoice may always be sent as ordinary invoices, including after 2028, on paper or as a PDF:
- invoices with a total of no more than €250 (§ 33 UStDV),
- tickets that count as invoices (§ 34 UStDV),
- invoices from small businesses under the Kleinunternehmer rule (§ 34a UStDV).
One point small businesses tend to miss: they don’t have to send e-invoices, but they do have to receive them. The ministry’s letter says the e-invoicing rules apply even when the recipient is a Kleinunternehmer (para. 17).
Is the deadline going to move?
As of September 2026, no. The German Confederation of Skilled Crafts (ZDH) published a position paper in August 2026 asking for the obligation for businesses above €800,000 to be pushed to 1 January 2028, and a regional chamber of crafts in Lower Saxony made the same demand. I’m not aware of any draft bill, and § 27(38) UStG is unchanged.
That could still change. I’d plan with the law anyway, not with a lobby position. If the delay comes, you’ve bought yourself a year of slack. If it doesn’t, you’re done.
What to do before January
The real risk here is the panic purchase in December. What you need is often already in the software you run; someone just has to check. This is the order I’d go in:
- Estimate your 2026 turnover. If you’re close to the threshold, treat yourself as above it.
- Check your existing invoicing software. Can your accounting tool or ERP produce XRechnung or ZUGFeRD in a valid profile? Often that’s a setting or an update, not a new product.
- Test with real customers. Send a few regular customers an e-invoice now and ask whether it arrives and processes cleanly. Mistakes in October are cheap. Mistakes in January end up in your customers’ bookkeeping.
- Sort out inbound and archiving at the same time. If you’re changing the process anyway, fix the receiving side and GoBD-compliant storage in the same pass.
Only if your current software can’t do it does new software come into the picture. Then take a sober look at whether an off-the-shelf product is enough, whether a tool under your own control fits better, or whether a small integration with your existing process is the lighter change. Signing up for a subscription just because January is getting closer is rarely the best of those options.
This is an overview, not tax advice. Check the turnover threshold and any special cases with your tax adviser.
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