# German E-Invoicing Mandate 2027: Are You Affected? 2-Minute Check | Norman
Source: https://norman.finance/de/en/e-invoicing/mandate-check

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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.

## 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 |

## 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.

1. **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.
2. **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.
3. **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](#erechnung-pflicht-quiz)

## 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.

## Related pages

- [E-invoicing mandate](https://norman.finance/de/en/e-invoicing/mandate): Germany's B2B e-invoicing mandate hits receiving from 2025 and sending from 2027 and 2028. Norman shows what applies when and runs it in the live workflow.
- [XRechnung](https://norman.finance/de/en/e-invoicing/xrechnung): Norman creates, sends, and receives XRechnung files under EN 16931, for German public-sector invoices, Leitweg-IDs, and the B2B mandate from 2025.
- [ZUGFeRD](https://norman.finance/de/en/e-invoicing/zugferd): Norman creates and receives ZUGFeRD invoices as PDF/A-3 with embedded EN 16931 XML, ready for the German B2B e-invoicing mandate from 2025, 2027, and 2028.
- [GoBD compliance](https://norman.finance/de/en/gobd-compliance): Norman meets GoBD: audit-proof receipt archiving, timestamped change history, procedure documentation, and structured data access for tax audits.
- [Small business](https://norman.finance/de/en/small-business): Simple bookkeeping, invoicing, and tax workflows for small businesses under Germany's Kleinunternehmer rules.
- [GmbH](https://norman.finance/de/en/gmbh): Norman automates bookkeeping, invoices, payments, and German tax workflows for GmbHs.
- [UG](https://norman.finance/de/en/ug): Norman automates bookkeeping, invoicing, payments, and German tax workflows for UGs.
- [Freelancers](https://norman.finance/de/en/freelancers): Automate invoices, receipts, bookkeeping, and German tax workflows as a freelancer.
- [Online stores](https://norman.finance/de/en/online-stores): Norman keeps Stripe, PayPal, and Shopify payouts, shipping and platform receipts, and tax workflows together for German online stores, from Etsy startup to GmbH.
- [Accounting](https://norman.finance/de/en/accounting): Norman keeps receipts, bank transactions, and categories connected, so your bookkeeping stays current week by week.