Germany E-Invoicing 2027: Who Must Issue E-Invoices
E-invoicing in Germany from 2027: who must issue e-invoices, how the €800,000 turnover test works, exemptions, the 2028 deadline and a readiness checklist.
Quick answer: For e-invoicing in Germany, the key date is 1 January 2027. From then, any business established in Germany whose total turnover in 2026 exceeded €800,000 must issue structured e-invoices (EN 16931 formats such as XRechnung or ZUGFeRD) for domestic B2B sales. Smaller businesses can keep using PDF or paper until 31 December 2027, and everyone must issue e-invoices from 1 January 2028.
Most German businesses already know the receiving rule from 2025. The question now is who has to send e-invoices from January, and whether you can still use a PDF from a tool like our free invoice generator. This guide focuses on the 2027 issuing obligation: how the €800,000 test works, which sales are in or out, and what to do in the next few weeks. For the format details, see our separate guide to XRechnung vs ZUGFeRD.
Important: This is general information, not tax or legal advice. The rules come from the Growth Opportunities Act (Wachstumschancengesetz), section 14 of the German VAT Act (UStG) and guidance letters from the Federal Ministry of Finance (BMF). Check the official BMF e-invoice FAQ or ask a Steuerberater before acting on any detail here.
E-invoicing in Germany: the 2025 to 2028 timeline
Germany phases the E-Rechnungspflicht (e-invoice obligation) in three steps. Receiving came first, then issuing for larger businesses, then issuing for everyone.
| Date | Who | What changes |
|---|---|---|
| 1 January 2025 | All businesses established in Germany | Must be able to receive e-invoices for domestic B2B purchases |
| Until 31 December 2026 | All businesses | May still issue paper invoices, or PDFs with the buyer's consent |
| 1 January 2027 | Businesses with 2026 total turnover above €800,000 | Must issue e-invoices for domestic B2B sales |
| Until 31 December 2027 | Businesses with 2026 turnover of €800,000 or less | May still issue paper or PDF invoices; agreed EDI invoices also remain possible for all |
| 1 January 2028 | All businesses | Must issue e-invoices for domestic B2B sales |
The pattern matches the wider European shift described in our e-invoicing guide: first make everyone able to receive, then require the larger senders, then everyone else.
Who must issue e-invoices in Germany from 2027?
You must issue e-invoices from 1 January 2027 if all of the following are true:
- You are a business established in Germany (registered office, management or a fixed establishment involved in the supply).
- Your customer is also a business established in Germany. The mandate covers domestic B2B supplies.
- The sale is not exempt from the invoicing obligation (see below).
- Your total turnover in 2026 was above €800,000.
If points 1 to 3 apply but your 2026 turnover was €800,000 or less, you are covered from 1 January 2028 instead. If point 1 or 2 fails, the German domestic mandate does not apply to that sale at all.
Selling to the public sector
Invoices to federal public authorities (B2G) have required XRechnung-type e-invoices for years, under separate public procurement rules, and many federal states have similar rules. That is not new in 2027, but if you already invoice public bodies you have a head start: the same software usually handles B2B e-invoices.
How the €800,000 turnover test works
The €800,000 threshold is the part most businesses get wrong. Three points matter:
- It is total turnover, not B2B turnover. Consumer sales, domestic B2B sales and cross-border sales all count towards the figure, as defined for the small business scheme (Gesamtumsatz).
- It is the previous calendar year. For 2027 the test year is 2026. Your 2027 sales do not change your status during 2027.
- It is a net figure. VAT is not added on top. Certain items, such as some exempt turnover and sales of business assets, are left out under the statutory definition.
Because the test looks at the whole business, a shop or tradesperson who sells mainly to consumers can still be caught. Only the B2B invoices need to be e-invoices, but the threshold is measured across everything.
New businesses and groups
Two situations are less clear-cut. A business that starts trading in 2027 has no 2026 figure; check the BMF guidance or ask an adviser how that is treated, and consider issuing e-invoices from the start. For VAT groups (Organschaft), the turnover of the group as a whole is generally relevant, so a small subsidiary in a large group should not assume it falls under €800,000.
Which invoices are exempt from the e-invoice obligation?
| Type of sale | E-invoice required? | What you can use instead |
|---|---|---|
| Sales to private consumers (B2C) | No | Paper or PDF |
| Small-amount invoices (Kleinbetragsrechnungen) up to €250 gross | No | Paper or PDF, simplified content |
| Passenger transport tickets | No | Ticket |
| Supplies by Kleinunternehmer | No (but must receive) | Paper or PDF |
| Many VAT-exempt supplies (for example certain financial or medical services) | Generally no | Paper or PDF, check the BMF list |
| Intra-EU and export sales | No, not under the domestic mandate | PDF with reverse charge or export wording |
| Domestic B2B sale above €250 by an in-scope business | Yes | XRechnung, ZUGFeRD (EN 16931 profile or higher) or compliant EDI |
For cross-border invoices, the wording matters more than the format. Our reverse charge invoice guide has the standard phrases.
Worked example: which invoices must be e-invoices in 2027?
A Cologne IT services company had these net sales in 2026:
| 2026 sales | Net (€) |
|---|---|
| IT support for German companies (domestic B2B) | 610,000 |
| Laptop repairs for private customers (B2C) | 145,000 |
| Software projects for clients in the Netherlands (intra-EU B2B) | 70,000 |
| Total turnover | 825,000 |
The maths: 610,000 + 145,000 + 70,000 = €825,000. That is €25,000 above the threshold, so from 1 January 2027 the company must issue e-invoices for its domestic B2B work.
A typical January invoice to a German client for a monthly support contract would be: net €4,000, VAT at 19% = 4,000 × 0.19 = €760, total €4,760. That invoice must be an XRechnung or a compliant ZUGFeRD file. A €180 repair for a private customer can still be a PDF, and so can the invoice to the Dutch client (with reverse charge wording). If the company's 2026 turnover had been €790,000 instead, all three could stay as PDFs until the end of 2027.
What counts as an e-invoice for the German mandate?
An e-invoice is an invoice issued, transmitted and received in a structured electronic format that complies with EN 16931 and allows automatic processing. In practice that means:
- XRechnung (pure XML, in UBL or CII syntax)
- ZUGFeRD 2.x with the EN 16931, EXTENDED or XRECHNUNG profile (PDF with embedded XML)
- Other formats agreed between the parties, such as EDI, if the data can be correctly converted to EN 16931
A PDF on its own, however professional, is an "other invoice" (sonstige Rechnung). Our explainer on e-invoice vs PDF invoice goes through the difference field by field. Germany does not prescribe a transmission channel, so email with an XML attachment, a portal or the Peppol network are all acceptable.
What should German businesses do before 1 January 2027?
Step 1: Calculate your 2026 total turnover
Do not wait for the annual accounts. Use your bookkeeping to project the full-year figure in November and December. If you are close to €800,000, treat yourself as in scope.
Step 2: List your domestic B2B customers
Pull a customer list and mark which ones are German businesses. Collect their invoice email addresses, buyer references and, for public bodies, the Leitweg-ID.
Step 3: Choose software that outputs a compliant format
Accounting and invoicing tools that export XRechnung or ZUGFeRD are widely available. Check that the tool validates the file, keeps your invoice numbering sequential and archives the XML.
Step 4: Test with two or three customers
Send test invoices in December and ask your customers to confirm their systems read them. Fix any missing fields, such as the buyer reference or payment terms.
Step 5: Set up archiving
The XML is the original invoice and must be kept unaltered for the statutory retention period. See how long to keep invoices.
Common mistakes with the 2027 deadline
- Measuring only B2B sales against €800,000. The test is total turnover.
- Assuming a ZUGFeRD file is always valid. MINIMUM and BASIC WL profiles do not qualify.
- Forgetting credit notes. Corrections to in-scope invoices also need to be structured. See our credit note guide.
- Leaving receiving until later. The duty to receive has applied since 2025, regardless of size.
- Treating foreign clients as in scope. The mandate is domestic; do not over-engineer invoices to non-German customers unless they ask.
Germany 2027 readiness checklist
- 2026 total turnover calculated or projected: above or below €800,000?
- Domestic B2B customers identified, with invoice addresses and references
- Software chosen that issues XRechnung or ZUGFeRD (EN 16931 profile or higher)
- Test invoices sent and accepted
- Process for credit notes and corrections in the same format
- XML archive in place for the full retention period
- PDF workflow kept for B2C, small-amount and cross-border invoices
Can a free invoice generator still help?
Yes, for the invoices outside the mandate. Our generator runs in your browser, needs no account and exports a PDF. It does not create XRechnung XML or ZUGFeRD files, so do not use it for domestic B2B invoices once the mandate applies to you. It remains useful for consumer invoices, small-amount invoices, quotes, proformas and invoices to clients abroad. Our 2027 e-invoicing mandates list shows where else PDF invoices are being phased out.
Next step
Work out your 2026 turnover this month. Above €800,000: pick and test e-invoicing software before Christmas. Below it: you have until 1 January 2028, but make sure you can receive and archive XML invoices now, and use the extra year to move over calmly.
Frequently asked questions
Does the €800,000 threshold include VAT?
The test uses your total turnover (Gesamtumsatz) as defined for the small business scheme in the German VAT Act, which is a net figure, so VAT itself is not counted. Certain exempt turnover and sales of fixed assets can be excluded under that definition. Ask your Steuerberater to confirm the figure from your 2026 books before you rely on staying under the line.
What if my business starts trading in 2027?
A business with no prior-year turnover has no 2026 figure to compare with €800,000, and the BMF guidance should be checked for how it treats new businesses. Many advisers recommend that start-ups simply issue compliant e-invoices for domestic B2B sales from day one, because every business will have to from 1 January 2028 anyway.
Can I keep sending PDF invoices to German clients after 2027?
For domestic B2B sales, only during the transition rules: until 31 December 2026 for everyone, and until 31 December 2027 if your 2026 turnover was €800,000 or less. After that, PDFs remain fine for consumers, small-amount invoices up to €250 and most cross-border sales, but not for domestic B2B invoices.
Are Kleinunternehmer affected by the 2027 rules?
Businesses using the small business scheme (Kleinunternehmerregelung) are exempt from the obligation to issue e-invoices. Since 2025 the scheme applies if prior-year turnover was no more than €25,000 and current-year turnover stays at or below €100,000. They must still be able to receive and archive e-invoices from their suppliers.
Is EDI still allowed after 1 January 2027?
EDI invoices that both parties have agreed can be used during the transition period until the end of 2027. From 2028 an EDI format is only acceptable if the required invoice data can be correctly extracted into an EN 16931-compliant format, so check with your EDI provider before then.
What happens if I issue a PDF when an e-invoice was required?
The invoice does not meet the legal requirements for an invoice, which can put your customer's input VAT deduction at risk and may be treated as an administrative offence. In practice, larger buyers are likely to reject the PDF and ask for a compliant e-invoice, which delays payment.
Do invoices to customers in other EU countries have to be e-invoices from 2027?
No. The German obligation covers domestic B2B supplies between businesses established in Germany. Invoices to customers in France, Austria or elsewhere in the EU, and to customers outside the EU, can still be PDF or paper under German rules, unless the customer's country requires otherwise. That changes for intra-EU B2B sales from 1 July 2030 under the EU's ViDA reform.
Do invoices to freelancers and sole traders count as B2B?
Yes, if the customer buys as a business (Unternehmer) for its business. A freelance designer, a doctor's practice or a sole trader is a business customer, so the e-invoice rules apply if you are above the €800,000 threshold, or from 2028 in any case. Sales to private individuals are B2C and are not covered. When in doubt, ask whether the purchase is for business use.
Do self-billing invoices (Gutschriften) have to be e-invoices?
Yes. A self-billed invoice, where the buyer issues the invoice on the supplier's behalf, is still an invoice for VAT purposes, so the e-invoice rules apply to it in the same way. Which transition date applies is generally linked to the supplier whose sale is being invoiced. If you use self-billing, for example with commission agents, confirm the details with your Steuerberater.
Do down-payment invoices have to be e-invoices?
Yes. Invoices for advance payments or deposits (Anzahlungsrechnungen) are invoices under German VAT law, so they follow the same rules as final invoices. If you are in scope from 2027, down-payment, partial and final invoices for domestic B2B work all need to be in a structured format. Make sure your software handles the link between advance payments and the final invoice correctly.
Invoice Creator Editorial Team
Guides on invoicing, cash flow and small-business finance from Invoice Creator, operated by Next Software Development Company. Content is reviewed for accuracy against the fields our own invoice generator produces.
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