The German e-invoicing mandate: when does it reach you?

From 1 January 2027, businesses with more than €800,000 in prior-year turnover must issue structured e-invoices; from 1 January 2028, everyone else. Five questions and you have your date. Status: 2026.

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Question 1 of 5

Are you a Kleinunternehmer under § 19 UStG?

Kleinunternehmer do not charge VAT. They are permanently exempt from having to issue e-invoices — but they still have to be able to receive them.

Yes, I use the small-business schemeNo, I charge VATI am not sure

All questions at a glance

Your situation

Five questions about status, customers, and turnover.

Are you a Kleinunternehmer under § 19 UStG?
Kleinunternehmer do not charge VAT. They are permanently exempt from having to issue e-invoices — but they still have to be able to receive them.
- Yes, I use the small-business scheme
- No, I charge VAT
- I am not sure
Do you invoice other businesses in Germany?
The obligation covers domestic B2B supplies only. Invoices to consumers and to customers abroad are out of scope.
- Yes, regularly
- Occasionally
- No, only consumers or customers abroad
What was your total turnover in 2026?
2026 is the year that decides the 2027 stage. Above €800,000 means the issuing duty starts on 1 January 2027.
- Above €800,000
- Up to €800,000
- Not settled yet
How large are your invoices, typically?
Small-value invoices up to €250 gross (§ 33 UStDV) may stay on paper or PDF permanently — even after 2028.
- Mostly above €250 gross
- Almost always below €250 gross
Can you already receive and archive e-invoices?
That means XRechnung and ZUGFeRD from version 2.0.1 (excluding the MINIMUM and BASIC-WL profiles). This duty has applied to every domestic business since 1 January 2025.
- Yes, that works
- No, not yet
- I don't know

All possible results

From 1 January 2027: you must issue e-invoices

Your 2026 turnover was above €800,000 and you invoice domestic business customers, so the transition period ends for you on 31 December 2026. From 1 January 2027 every B2B invoice has to go out as a structured e-invoice under EN 16931 — a PDF by email will no longer qualify.

Permitted: XRechnung and ZUGFeRD from 2.0.1, but not the MINIMUM and BASIC-WL profiles
Still exempt: invoices up to €250 gross, travel tickets, and B2C
The structured part must be kept unaltered for 8 years (§ 14b UStG)
EDI procedures remain permitted until the end of 2027, then no longer

Norman generates XRechnung and ZUGFeRD from your ordinary invoices and archives them GoBD-compliant. Invoicing is free, with no limits.

This test is orientation, not tax advice. What counts is your actual 2026 total turnover under § 19 (3) UStG.

From 1 January 2028: you get one more year

Your 2026 turnover was up to €800,000, so the extended transition period runs for you until 31 December 2027. Until then you may keep sending paper or PDF. From 1 January 2028 the issuing duty applies regardless of turnover.

You already have to receive e-invoices, though — that duty has been running since 2025
Your business customers above €800,000 switch in 2027, so expect many more incoming e-invoices from then
Permitted: XRechnung and ZUGFeRD from 2.0.1, but not the MINIMUM and BASIC-WL profiles
The structured part must be kept unaltered for 8 years (§ 14b UStG)

Switching early pays off on the receiving side: incoming e-invoices get read and booked automatically.

This test is orientation, not tax advice. If your 2026 turnover does exceed €800,000, the duty starts in 2027 after all.

You don't have to issue them — but you do have to receive them

The issuing duty does not reach you: under § 34a UStDV, Kleinunternehmer may keep using the "other invoice" indefinitely, and invoices to consumers or to customers abroad fall outside the rule anyway. The other half still applies: since 1 January 2025 every domestic business must be able to receive and store e-invoices.

Formally an email address is enough to receive them — the retention is the real work
The structured part must be kept unaltered for 8 years (§ 14b UStG)
You may issue e-invoices voluntarily, and many business customers prefer it
If you later move to standard VAT taxation, the issuing duty applies from 2028

Norman receives e-invoices, reads them, and archives them GoBD-compliant. Accounting and invoicing are free.

This test is orientation, not tax advice. Small-business status is determined under § 19 UStG.

The three stages of the mandate

Receiving already applies to everyone. Issuing arrives in turnover-based stages.

	Since 1 Jan 2025	From 1 Jan 2027	From 1 Jan 2028
Receiving e-invoices	Mandatory for every domestic business	Mandatory	Mandatory
Issuing e-invoices (B2B)	Voluntary: paper and PDF still allowed	Mandatory above €800,000 prior-year turnover (2026)	Mandatory for all, regardless of turnover
Kleinunternehmer (§ 19 UStG)	Receive yes, issue no	Permanently exempt from issuing	Permanently exempt from issuing
EDI procedures	Permitted	Still permitted, final year	No longer permitted
Invoices up to €250 gross	Paper or PDF allowed	Still allowed (§ 33 UStDV)	Still allowed (§ 33 UStDV)
Invoices to consumers (B2C)	Out of scope	Out of scope	Out of scope

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The six things that set your deadline

First the status, then the turnover, then the format.

€800,000 turnover in 2026

The threshold for the 2027 stage is your total turnover in the prior year, 2026. Above it, the transition period ends for you on 31 December 2026. Up to €800,000 you get one more year.

Domestic B2B only

The obligation covers supplies between domestic businesses. Invoices to consumers, to legal entities that are not businesses, and to customers abroad are out of scope.

Kleinunternehmer are exempt

Small businesses under § 19 UStG never have to issue e-invoices: § 34a UStDV explicitly permits them to send an "other invoice". The receiving duty applies to them too, though, and it has since 1 January 2025.

XRechnung and ZUGFeRD from 2.0.1

Any structured format compliant with EN 16931 qualifies. In Germany that means XRechnung and ZUGFeRD from version 2.0.1 — explicitly not the MINIMUM and BASIC-WL profiles, which do not carry a complete invoice.

A PDF is not an e-invoice

A PDF emailed to a customer remains an "other invoice", however digital the delivery. What counts is the machine-readable structured data set, not the transmission channel.

Eight years, unaltered

The structured part of an e-invoice must be retained for eight years in its original form (§ 14b UStG). Since the GoBD amendment of July 2025, archiving the XML component is sufficient.

How to prepare

Three steps, whether your date is 2027 or 2028.

Sort out receiving

This duty has been running since 2025. Check that incoming XRechnung and ZUGFeRD files reach you, get parsed, and are stored in an audit-proof way. An email address is formally enough to receive them, but not to retain them.

Establish your 2026 turnover

Your total 2026 turnover decides whether you must issue from 1 January 2027 or only from 2028. If you are close to €800,000, plan for the earlier deadline.

Switch outgoing invoices over

With Norman, XRechnung and ZUGFeRD come straight out of your ordinary invoices, with no separate compliance project. Incoming e-invoices are recognized, booked, and archived GoBD-compliant.

Not sure when it reaches you?

Five questions and you have your date: 2027, 2028, or never.

Start the check now

Frequently asked questions

When exactly does the 2027 e-invoicing obligation start?

From 1 January 2027, businesses whose total turnover in 2026 exceeded €800,000 must issue B2B invoices as structured e-invoices. For every other domestic business the duty starts on 1 January 2028. The duty to receive e-invoices has applied to everyone since 1 January 2025.

What counts toward the €800,000?

Total turnover in the prior year, 2026, as defined in § 19 (3) UStG. It is the issuer's turnover that matters, not the recipient's. Below that figure in 2026, the extended transition period runs for you until 31 December 2027.

Is a PDF sent by email an e-invoice?

No. A PDF counts as an "other invoice", whether it arrives by email or on paper. An e-invoice under § 14 UStG is a structured, machine-readable data set compliant with EN 16931. A PDF with embedded XML (ZUGFeRD from 2.0.1) does meet the requirement.

Which formats are permitted?

Any format compliant with EN 16931. In Germany that primarily means XRechnung and ZUGFeRD from version 2.0.1. The ZUGFeRD MINIMUM and BASIC-WL profiles are explicitly not sufficient, because they do not represent a complete invoice. Other formats are permitted if both parties agree and the required VAT details can be extracted correctly.

Do Kleinunternehmer have to issue e-invoices?

No. § 34a UStDV, inserted by the Jahressteuergesetz 2024, explicitly allows Kleinunternehmer under § 19 UStG to keep transmitting their invoices as an "other invoice", meaning paper or PDF. The exemption has no end date. Like every other domestic business, though, they must be able to receive e-invoices, and have had to since 1 January 2025.

Which invoices are exempt from the obligation?

Small-value invoices up to €250 gross (§ 33 UStDV), travel tickets (§ 34 UStDV), invoices to consumers (B2C), invoices to legal entities that are not businesses, supplies abroad, and many supplies exempt under § 4 nos. 8 to 29 UStG.

How long must e-invoices be retained?

Eight years (§ 14b (1) UStG). At minimum the structured part must be retained, intact and in its original form. Since the second GoBD amendment of 14 July 2025, archiving the structured data component is sufficient provided the other GoBD requirements are met.

What happens if I miss the deadline?

An invoice issued after the cut-off in the wrong format is not a proper invoice for VAT purposes. That can put your customer's input-VAT deduction at risk until a correct e-invoice is provided. In practice the exposure is less a fine than an invoice your customer rejects.