E-invoicing mandate 2027 & 2028
Sending obligation, turnover thresholds and how to prepare in time
Key takeaways
- Since 2025: All domestic B2B companies must be able to receive e-invoices – with no transition period.
- From 2027: Sending obligation for companies with more than €800,000 prior-year turnover.
- From 2028: Sending obligation for all remaining domestic B2B companies – including small businesses.
- Format: Permitted are structured formats per EN 16931, primarily XRechnung and ZUGFeRD (from the EN 16931 profile).
The 2025–2028 timeline at a glance
With the Growth Opportunities Act, e-invoicing was introduced in stages for domestic B2B business. The receiving obligation already applies; the sending obligation phases in by company size.
| From | Obligation |
|---|---|
| 01.01.2025 | Receiving obligation for all B2B companies |
| 01.01.2027 | Sending obligation if > €800,000 turnover (2026) |
| 01.01.2028 | Sending obligation for all remaining B2B companies |
What changes in 2027?
From 1 January 2027, companies with a prior-year (2026) turnover of more than €800,000 must send their B2B invoices as structured e-invoices. Simple PDF or paper invoices are then no longer permitted in this segment. The previously possible EDI special arrangement continues, provided the data records can be extracted in an EN 16931-compliant way.
What changes in 2028?
From 1 January 2028 all transition periods end: all domestic B2B companies must then send e-invoices – regardless of turnover. This explicitly also affects small businesses under § 19 UStG and freelancers. By this point at the latest, every self-employed person should use software that produces XRechnung or ZUGFeRD.
Who is affected by the sending obligation?
- All companies established in Germany with B2B sales.
- Including small businesses and freelancers (from 2028).
- Also associations with a commercial business operation.
- Not affected: pure B2C invoices to private customers.
How to prepare
Don't wait until the deadline. Switching early avoids stress and brings immediate benefits: faster payment and less paperwork. Modern invoicing software creates XRechnung and ZUGFeRD automatically – you write the invoice as usual.
Frequently asked questions
When does the mandate apply to small businesses?
Small businesses have had to receive e-invoices since 2025. The sending obligation applies to them from 1 January 2028.
What is the turnover threshold for 2027?
Anyone with more than €800,000 total turnover in 2026 must send e-invoices from 2027. Below that, the 2028 deadline applies.
Are PDF invoices still allowed from 2027/2028?
In the B2B area, no longer for the affected companies. A plain PDF does not count as an e-invoice – a structured format such as XRechnung or ZUGFeRD is required.
Does the obligation also apply to invoices to private customers?
No. B2C invoices to private individuals are exempt from the e-invoicing mandate.
What happens in case of non-compliance?
A non-compliant invoice can jeopardise the recipient's input tax deduction and lead to objections. It can also delay payment.
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