E-invoicing in Germany: what applies in 2027 and 2028
Germany already requires every business to be able to receive structured e-invoices for domestic B2B supplies. The transition periods for issuing them end on 31 December 2026 and 31 December 2027. This guide sets out the dates, the formats and the practical steps, with links to the official sources.
The legal basis in brief
The Growth Opportunities Act (Wachstumschancengesetz) rewrote section 14 of the German VAT Act (UStG). Since 1 January 2025, an e-invoice in Germany means an invoice issued, transmitted and received in a structured electronic format that allows automatic processing. A PDF sent by email is no longer an e-invoice in this sense; it counts as an “other invoice” (sonstige Rechnung).
The Federal Ministry of Finance (BMF) has set out how it applies the rules in two administrative letters, dated 15 October 2024 and 15 October 2025, and maintains an FAQ page. The transition periods are in section 27(38) UStG.
Timeline
| Date | Who | What |
|---|---|---|
| 1 January 2025 | All businesses established in Germany | Must be able to receive e-invoices for domestic B2B supplies. An email inbox is enough. |
| Until 31 December 2026 | All issuers | Paper invoices remain allowed; other electronic formats (e.g. plain PDF) need the recipient’s consent. |
| 1 January 2027 | Businesses with prior-year total turnover above €800,000 | Must issue e-invoices for domestic B2B supplies. |
| Until 31 December 2027 | Businesses with prior-year total turnover up to €800,000; users of EDI | May still issue paper or other formats (with consent); existing EDI procedures remain allowed for everyone. |
| 1 January 2028 | All businesses | E-invoice issuing obligation applies in full for domestic B2B supplies. |
The transition periods refer to the date of the supply, not the date of the invoice. Sources: section 27(38) UStG and the BMF letter of 15 October 2025.
Who is affected, and what is exempt
The rules cover invoices between businesses established in Germany for supplies that are taxable in Germany. Invoices to consumers (B2C) are not covered. Cross-border invoices are outside the domestic obligation.
- Small-amount invoices with a total of up to €250 may always be issued as an “other invoice” (section 33 UStDV).
- Small businesses under the Kleinunternehmer scheme may issue “other invoices” (section 34a UStDV). They must still be able to receive e-invoices.
- Travel tickets (Fahrausweise) are also excluded from the issuing obligation, according to the BMF.
Accepted formats
The format must comply with the European standard EN 16931 (EN 16931-1:2017). In practice, two formats dominate:
- XRechnung, the German CIUS of EN 16931, as pure XML (UBL 2.1 or UN/CEFACT CII D16B syntax).
- ZUGFeRD from version 2.0.1, a PDF/A-3 with embedded XML. The profiles MINIMUM and BASIC WL do not qualify as e-invoices. The current version is ZUGFeRD 2.5.2, technically identical to Factur-X 1.09.2 (FNFE-MPE).
Other structured formats, including EDI or Peppol BIS Billing 3.0, may be agreed between the parties, provided the invoice data can be extracted correctly and in a way compatible with EN 16931.
What to do now
- Check your prior-year total turnover to see whether 1 January 2027 or 1 January 2028 applies to you.
- Ask your accounting or ERP provider whether it can create XRechnung or ZUGFeRD (EN 16931 profile or higher) and when.
- Set up a dedicated inbox or channel for incoming e-invoices and tell your suppliers about it.
- Archive the XML file itself. Under the GoBD rules, the structured data is the original; a printout or visualisation is not.
- Test a few real invoices with your largest customers before your deadline.
What changes for recipients
Recipients cannot refuse an e-invoice in a valid format. Input VAT deduction still requires a proper invoice, so accounts payable teams need to read the XML, check the mandatory content and keep the file unchanged. For hybrid ZUGFeRD files, the embedded XML is what counts.
Common mistakes
- Treating a PDF sent by email as an e-invoice.
- Archiving only the PDF view and discarding the XML.
- Using ZUGFeRD MINIMUM or BASIC WL for invoices that must be e-invoices.
- Waiting for a postponement that has not been adopted.
How our viewer and validator help
Open an XRechnung in the XRechnung viewer to read it as a normal invoice, or check it against the rules in the XRechnung validator. For hybrid PDFs use the ZUGFeRD viewer and the Factur-X validator.
Frequently asked questions
Do I need special software to receive e-invoices?
Not necessarily. According to the BMF, providing an email inbox is sufficient to meet the receiving obligation. You do, however, need a way to read and archive the XML.
Is a PDF invoice still allowed in 2027?
Only if your prior-year total turnover was €800,000 or less, with the recipient’s consent, or for the exempt cases. From 1 January 2028 the transition ends for all businesses.
Which turnover counts for the €800,000 threshold?
The total turnover of the previous calendar year as defined in section 19(2) UStG, according to section 27(38) no. 2 UStG.
Will the 2027 deadline be postponed?
A postponement has been requested by the crafts sector, but as of 28 October 2026 none has been adopted.
Is Peppol mandatory in Germany?
No. Germany does not prescribe a transmission channel. Peppol is one possible channel among others, such as email.
Do the rules apply to invoices to consumers?
No. The e-invoicing obligation covers domestic B2B supplies only.
Sources
- BMF letter of 15 October 2025 on the mandatory e-invoice (checked 2026-10-28)
- BMF FAQ on the e-invoice (checked 2026-10-28)
- Section 27 UStG (transition rules, para. 38) (checked 2026-10-28)
- Section 33 UStDV (small-amount invoices) (checked 2026-10-28)
- Section 34a UStDV (small businesses) (checked 2026-10-28)
- German Bundestag lobby register, ZDH statement (checked 2026-10-28)
- FNFE-MPE: Factur-X / ZUGFeRD (checked 2026-10-28)
Last reviewed 28 October 2026