Issuing E-Invoices: Preparing for the Mandatory Rollout in 2027/2028

Companies that until now only had to receive e-invoices face the next stage: starting in 2027, or at the latest 2028, many companies will have to create and send structured e-invoices to their business partners themselves.

In short: from 2027, companies with prior year revenue above 800,000 euros must issue their own e-invoices; from 2028, the obligation applies to all remaining companies; small businesses (Kleinunternehmer) remain permanently exempt. Until the end of 2027, paper or PDF invoices are only permitted with the recipient's consent. Anyone who ignores the obligation risks VAT related objections.

Who is affected by the obligation to issue e-invoices?

In principle, all VAT liable companies that issue invoices to other businesses are affected; the obligation is being phased in based on revenue level. From 2027, it applies to companies with prior year revenue above 800,000 euros, and from 2028 to all remaining companies. The prior year's revenue is always the deciding factor, so companies should determine early which tier they fall into instead of only calculating it shortly before the respective deadline. Small businesses remain permanently exempt from the obligation to issue e-invoices but must still be able to receive incoming e-invoices. Getting an early overview avoids last minute rushing before the respective deadline and allows the software transition to be planned calmly. A tool such as Company Audit shows exactly which of these and other obligations apply to your company.

What counts as an e-invoice, and what does not?

An e-invoice within the meaning of the reform is a structured, machine readable format, not a scanned paper invoice and not a simple PDF file. The formats in question are primarily XRechnung and ZUGFeRD from version 2.0.1 onward; both can be read in, checked, and processed further in accounting automatically. An invoice sent as a PDF does not meet the requirements of the issuing obligation and, from the respective deadlines, may only be sent if the recipient explicitly agrees. Anyone who already invoices public sector clients is often already familiar with structured formats and Leitweg IDs from the B2G sector; this knowledge can be applied directly to the B2B issuing obligation.

What exactly do you need to do?

The transition mainly affects software, master data, and internal processes. Five steps make your company ready to issue e-invoices:

1. Check when your own issuing obligation takes effect; what matters is whether prior year revenue is above or below 800,000 euros.
2. Switch your invoicing or accounting software to generate XRechnung or ZUGFeRD (from version 2.0.1 onward).
3. Complete master data such as Leitweg IDs and buyer details so structured invoices can be created and delivered correctly.
4. Obtain and document customer consent to paper or PDF invoices for the transition period.
5. Archive outgoing e-invoices in a way that complies with GoBD requirements.

Since many companies have already implemented the ability to receive e-invoices, issuing them often only requires a software update rather than a completely new purchase; starting early spares you stress shortly before your respective deadline. Also clarify early with your software or tax advisory partner which interfaces and templates your accounting needs. Working through the steps one by one makes you ready to issue e-invoices in good time before your own deadline, whether that is 2027 or 2028.

By when do you need to make the switch?

The deadline depends on your prior year revenue. Companies with prior year revenue above 800,000 euros must issue their own e-invoices from 2027, all other VAT liable companies at the latest from 2028. Until the end of 2027, you may still send paper or PDF invoices, but only if the recipient explicitly agrees. After that, the structured e-invoice becomes the binding standard in business dealings between companies, and the previous transitional arrangement ends. Anyone who switches ahead of their own deadline benefits from a longer test phase and can use the transition period as a buffer instead of switching to the new software under time pressure.

What happens if you fail to comply?

Incorrect or missing e-invoices lead to VAT related objections. The obligation to issue e-invoices is set out in Section 14 UStG (German VAT Act) in conjunction with Section 34a UStDV; anyone who fails to implement it in time risks queries and objections to their invoicing during a review by the tax authorities. Switching software, master data, and archiving early avoids such objections from the outset. The earlier these three building blocks are in place, the lower the risk of recurring objections in future reviews.

Frequently asked questions

Do I have to issue e-invoices as a small business (Kleinunternehmer)?

No. Small businesses are permanently exempt from the obligation to issue e-invoices. They must, however, still be able to receive incoming e-invoices.

Which format counts as an e-invoice?

Structured electronic formats such as XRechnung or ZUGFeRD from version 2.0.1 onward count as e-invoices; a simple PDF file, by contrast, does not meet the requirements, even if it contains all the details of a normal invoice in terms of content.

Am I still allowed to send PDF invoices?

That is possible until the end of 2027, but only with the recipient's explicit consent. After that, the e-invoice becomes mandatory for the companies affected.

From when exactly does the obligation apply to my company?

If your prior year revenue is above 800,000 euros, the obligation takes effect from 2027. All other VAT liable companies must issue their own e-invoices at the latest from 2028. The revenue of the respective prior year is always the deciding factor.

What happens if my e-invoices are incorrect?

Incorrect or missing e-invoices can lead to VAT related objections. That is why an early switch of software, master data, and archiving pays off.

Source: Section 14 UStG, Section 34a UStDV. This article is general information and does not replace legal advice for individual cases. As of: July 2026.