E-invoicing mandate 2027 and 2028: deadlines and exceptions
German businesses must receive e-invoices since 2025 and issue them from 2027 or 2028, depending on turnover. Deadlines, exceptions and official sources.
What an e-invoice is
An e-invoice is an invoice issued, transmitted and received in a structured electronic format that allows electronic processing (§ 14(1) sentence 3 UStG, the German VAT Act). The format must follow the European standard – or be agreed between the parties, if the details can be extracted correctly and completely into a standard-conforming format (§ 14(1) sentence 6 UStG). A PDF on its own is not an e-invoice but an "other invoice" (§ 14(1) sentence 4 UStG).
According to the FAQ of the Federal Ministry of Finance, XRechnung and ZUGFeRD from version 2.0.1 meet the requirements – except the ZUGFeRD profiles MINIMUM and BASIC-WL.
The deadlines
| Period | What applies |
|---|---|
| since 1 January 2025 | Every business must be able to receive e-invoices. An e-mail inbox is enough. |
| supplies in 2025 and 2026 | Instead of an e-invoice, a paper invoice or – with the recipient's consent – another electronic invoice (e.g. a PDF) is allowed if it is transmitted by 31 December 2026 (§ 27(38) no. 1 UStG). |
| supplies in 2027 | This still applies to invoices transmitted by 31 December 2027 if the issuer's total turnover in the previous year was at most €800,000 (§ 27(38) no. 2 UStG). EDI remains allowed with the recipient's consent until the end of 2027 (no. 3). |
| from 1 January 2028 | E-invoices are mandatory for supplies between domestic businesses – without a turnover threshold, with the exceptions below. |
So the date of transmission matters too: a supply in December 2026 invoiced in January 2027 no longer falls under no. 1. There is no transition period for receiving.
Who is affected
The mandate covers supplies between businesses that are both established in Germany (§ 14(2) sentence 2 no. 1 UStG). Private consumers are not affected.
According to the Federal Ministry of Finance's FAQ (question "Are there exceptions to the mandatory e-invoice?"), no e-invoice is needed, among others, for:
- many tax-free supplies under § 4 nos. 8 to 29 UStG, such as financial services or tax-free letting – usually there is no invoicing obligation at all,
- small invoices up to €250 gross (§ 33 UStDV),
- tickets that count as invoices (§ 34 UStDV),
- invoices of small businesses under the small business scheme (§ 34a UStDV),
- supplies to legal persons that are not businesses, and certain property-related supplies to consumers.
What 2026 added
The Federal Ministry of Finance has explained the introduction in three letters: of 15 October 2024, of 15 October 2025 and – with supplementary rules – of 15 October 2026. The latest letter leaves the transition periods unchanged. Among other things it covers:
- Gross prices (such as fixed-price books): because XRechnung and ZUGFeRD have no format for them yet, it is not objected until 31 December 2027 if the structured part contains only the totals per tax rate. The line items must then be in an embedded readable annex that yields those totals and to which the structured part clearly refers (para. 19).
- Final invoices after down payments: easements for stating the partial payments apply until 30 June 2030 (paras. 3 and 4).
Frequently asked questions
Do I have to issue e-invoices in 2027 already?
Yes, if your total turnover in 2026 was above €800,000. If it was at most €800,000, you may still issue paper invoices or – with the recipient's consent – PDF invoices for supplies in 2027, as long as you transmit them by the end of 2027. EDI with consent is possible until the end of 2027 as well. From 2028 the mandate applies without a turnover threshold.
Is an e-mail inbox enough for receiving?
Yes. According to the Federal Ministry of Finance's FAQ an e-mail inbox is enough. You can read and validate the files with our free check, for example.
Is a PDF invoice an e-invoice?
No. A plain PDF is an other invoice. A ZUGFeRD file is a PDF too, but it also carries the structured invoice data as XML – that makes it an e-invoice.
Sources
- § 14 UStG and § 27(38) UStG (gesetze-im-internet.de, German)
- § 33 UStDV and § 34a UStDV
- FAQ on the e-invoice (Federal Ministry of Finance, German)
- BMF letter of 15 October 2025 and of 15 October 2026
As of 19 October 2026. This guide is not tax advice.
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