You have long been required to receive e-invoices. Most companies will have to send them from 1 January 2027. Here you will find what applies when — and how this can mean less work rather than more.
What applies when
since 1 Jan 2025
Receiving — no transition period
Every domestic company must be able to receive e-invoices. There is no grace period and no exception for this, not even for small-business owners (Kleinunternehmer). Anyone who cannot receive them technically or refuses to accept them has, according to the Federal Ministry of Finance (BMF), no entitlement to a non-electronic invoice (the statutory term for paper or a plain PDF) — the issuer’s obligation is nonetheless deemed fulfilled if they can demonstrably show they attempted delivery.
until 31 Dec 2026
Sending — paper and PDF still permitted
During this period every invoice issuer may still issue a non-electronic invoice instead of an e-invoice. This transition period is now ending for most companies.
from 1 Jan 2027
Obligation to send from € 800,000 turnover
Anyone whose total turnover in the previous year exceeded 800,000 euros must issue e-invoices in domestic B2B transactions. Smaller companies have until 31 Dec 2027, as do non-standard-compliant EDI procedures.
from 1 Jan 2028
Obligation to send for everyone
The transitional rules end. Every domestic B2B invoice must then be issued in a structured form in accordance with EN 16931.
And if you are below 800,000 euros?
Then you have more time — but only for sending. It depends on which of the two cases you fall under; they are regularly confused.
Turnover up to € 800,000
One year’s reprieve
If your total turnover in the previous year did not exceed 800,000 euros, you may continue to issue non-electronic invoices until 31 Dec 2027 — one year longer than larger companies. From 1 Jan 2028 the obligation applies to you too. This is a reprieve, not an exemption.
This is anyone who stayed below 25,000 euros in the previous year and stays below 100,000 euros in the current year. Under § 34a UStDV their invoices may always be transmitted as a non-electronic invoice — not a transition period, but a permanent exemption.
These two cases are confused most often, so here is an example: A GmbH with 50,000 euros in turnover is not a Kleinunternehmer — not because of its legal form, but because 50,000 is above the previous-year threshold of 25,000 euros. It falls into the first case: a reprieve until the end of 2027, then an obligation from 2028. The same GmbH with 20,000 euros in turnover would indeed be a Kleinunternehmer and permanently exempt. Here the law recognizes no legal form, only turnover — a GmbH can be a Kleinunternehmer, while a sole proprietorship may long since have ceased to be one.
That sounds wrong, and the misconception is widespread: a corporation and “small” — does that fit? For VAT purposes, yes. It gets confused with the small trader (Kleingewerbetreibender) of commercial law — and that one can indeed never be a GmbH, because under § 6 HGB a GmbH is always a merchant by legal form (Formkaufmann), no matter how small the business is. Two terms, two areas of law: small trade (Kleingewerbe) is commercial law, Kleinunternehmer is VAT law. For e-invoicing only the second one counts, and there § 2 UStG defines the entrepreneur explicitly “irrespective of whether it has legal capacity under other provisions”.
One catch remains: anyone who has waived the small-business scheme (Kleinunternehmerregelung) — as many do because of the input tax deduction — is also no longer a Kleinunternehmer and therefore not exempt. If you are unsure which case applies to you, your tax advisor will know for certain; we do not give advice on this.
What applies in both cases: you must be able to receive them — since 1 January 2025, without exception, even as a Kleinunternehmer. Whoever sends you an e-invoice has fulfilled their obligation; whether you can handle it is your concern.
And a trap that becomes costly during the transition: you may send paper without further ado — a PDF only if the recipient agrees. Anyone who quietly switches to PDF because it is, after all, digital ends up worse off than with paper.
A PDF is not an e-invoice
This is the misconception that costs the most money. An e-invoice is a structured data record in accordance with the EN 16931 standard — machine-readable, not merely digital. A paper printout and a plain PDF are, according to the Federal Ministry of Finance ↗, explicitly a non-electronic invoice, not an e-invoice. Anyone who considers their PDF done has not made the switch.
In Germany two formats mainly meet the requirements: XRechnung — pure XML, common in public procurement — and ZUGFeRD from version 2.0.1 onward, a PDF with embedded XML that humans and machines can read at the same time. With ZUGFeRD there is a detail that is readily overlooked: the MINIMUM and BASIC-WL profiles are not sufficient for VAT purposes. Anyone who sends with those does not fulfill the obligation — even though it says ZUGFeRD everywhere.
Being able to receive is not the same as arriving
Setting up a mailbox takes an afternoon. After that the real work begins: the invoice has to be checked, assigned to accounts, approved and archived — in an audit-proof way, with the structured data record as the authoritative original. This is exactly where the backlog arises. Many businesses meet the obligation to receive in a formal sense and then re-key the XML data by hand. That is more expensive than before.
What we make of it
Incoming invoices — whether XRechnung, ZUGFeRD, PDF or paper scan — we accept automatically, read out and assign to accounts: supplier, amount, tax, general ledger account, cost center. For outgoing invoices we generate and send in the required format, including an approval workflow, duplicate checking and handover to accounting. What used to take hours or days runs in seconds.
This is made possible by process know-how from sales and finance plus experience with DATEV, SAP and Oracle — we understand the document, the account and the process behind it, not just the technology. And the recognition runs locally on our systems (regex, OCR, our own AI), not in someone else’s cloud: your invoices reveal turnover, margins and suppliers — they do not belong on third-party servers.
You can also check an invoice right here, against EN 16931 — upload or paste, and the report appears at once.
Sources
Everything on this page can be verified — here are the references we rely on. Anyone consulting a service provider about e-invoicing should be able to demand exactly that.
§ 14 UStG ↗ — the legal definition: what an e-invoice is and what it is not.
§ 2 UStG ↗ — who even counts as an entrepreneur — “irrespective of whether it has legal capacity under other provisions”. That is why the legal form plays no role here.
§ 27 Abs. 38 UStG ↗ — the transitional rules — here the deadlines and the 800,000-euro threshold are set out in the text of the law.
§ 19 UStG ↗ — who is a Kleinunternehmer: 25,000 euros in the previous year, 100,000 euros in the current year — a question of turnover, not of legal form.
§ 34a UStDV ↗ — the permanent exemption for small-business owners: their invoices may “always” be transmitted as a non-electronic invoice.
FAQ of the Federal Ministry of Finance ↗ — the official interpretation for practice: obligation to receive without a transition period, PDF as a non-electronic invoice, permissible formats and profiles.
BMF circular of 15 Oct 2025 (PDF) ↗ — the current introductory circular — it states, among other things, that a recipient without the means to receive has no entitlement to a non-electronic invoice.
XRechnung (KoSIT) ↗ — the standard itself, maintained by the Coordination Office for IT Standards (KoSIT).
ZUGFeRD (FeRD) ↗ — the hybrid format with its profiles — including the two that are not sufficient.
You would rather not build this yourself? Talk to us — we take care of receiving, checking and sending your e-invoices.
As of: July 2026. This page reflects the current state of affairs and does not replace tax or legal advice. For your individual case — for instance the question of whether the 800,000-euro threshold applies to you — speak with your tax advisor; for the technical implementation, speak with us.