E-invoicing: Deadlines and transitional arrangements for issuing e-invoices
Receiving e-invoices has long been compulsory. When it comes to sending them, the date from which you must switch depends on the year and your turnover.
Introduction
From 2025, e-invoicing will be the norm for domestic business-to-business (B2B) transactions. Whilst there is no transition period for receiving e-invoices, the law provides for phased transition periods for sending your own invoices, running until the end of 2026 or the end of 2027 respectively.
This article explains when you must start sending e-invoices, what is permitted in the meantime, and what you should be prepared for regarding your outgoing invoices. We will support you with the technical set-up and integration with DATEV.
First, a few clarifications, as there are often misunderstandings regarding outgoing invoices:
E-invoicing is not just a 2028 issue: you have been required to receive e-invoices since 2025, and for larger businesses, the obligation to send them begins as early as 2027. For VAT purposes, a PDF file is not an e-invoice but is classified as a standard invoice – even if it looks professional and contains all the required details.
If your turnover is below the €800,000 threshold, you may continue to send PDF or paper invoices until the end of 2027 – but your business customers are not obliged to accept them. Invoices to private customers (B2C) are not affected by the e-invoicing requirement in any case.
Below, we’ll first distinguish between receiving and sending invoices, outline the transition periods, and explain why the second deadline for outgoing invoices leaves little room for manoeuvre in practice.
Receiving and sending are two separate obligations
When it comes to e-invoicing, two obligations are often conflated, though they should be considered separately. The obligation to be able to receive and process e-invoices has applied to all domestic businesses since 1 January 2025 – with no transition period and regardless of size.
For receiving e-invoices, an email inbox to which suppliers send the structured file is generally sufficient. You must therefore be able, from 2025, to receive and store an XRechnung or a ZUGFeRD file.
The obligation to issue and send e-invoices yourself, however, only comes into effect once the transition periods have expired. When this applies to you depends on the year and your turnover in the previous year.
You should ensure you can receive e-invoices regardless of whether you are sending them yourself. Suppliers can already send you e-invoices today, and a file that cannot be accessed delays processing and the input VAT deduction.
The transition periods for outgoing invoices
The law provides for a phased introduction for the issuing of invoices (Section 27(38) of the German Value Added Tax Act (UStG)). During the transitional period, you may still send paper or PDF invoices under certain conditions; after that, only structured e-invoices in accordance with the European standard EN 16931 will be permitted.
The following table summarises which option is permitted during which period.
| Period (transaction carried out) | Issuer | Permitted for outgoing invoices |
|---|---|---|
| 2025 and 2026 | All businesses | Paper invoice; with the recipient’s consent, PDF or other electronic formats are also permitted |
| 2027 | Total turnover in 2026 up to €800,000 | as in 2025/2026 (paper; PDF with consent) |
| 2027 | Total turnover in 2026 over €800,000 | e-invoicing only (structured format in accordance with EN 16931) |
| from 2028 | All businesses | Electronic invoicing only (subject to exceptions) |
By the end of 2026: all issuers
For transactions carried out in 2025 or 2026, you may continue to send paper invoices. A PDF or other unstructured format is also permitted, but only with the recipient’s consent.
This consent may also be implied, for example if the recipient pays the PDF invoice without objection.
From 2027: the €800,000 threshold
From 2027, the rules will depend on the previous year’s turnover. What counts is the total turnover for 2026: if it exceeds 800,000 euros, you must issue e-invoices in the B2B sector from 1 January 2027.
If your total turnover for 2026 is 800,000 euros or less, the transitional arrangement for you is extended until 31 December 2027. This means you may continue to send paper invoices – or, with the recipient’s consent, PDF invoices – during that year.
The threshold is based on the previous year’s total turnover, not the current year. Anyone whose turnover in 2026 is just over 800,000 euros will be required to issue e-invoices in 2027 – even if turnover falls again afterwards.
Special case: EDI procedures
Businesses that exchange invoices via an established EDI process may continue to use this under the statutory conditions until the end of 2027, even if it does not yet fully comply with the new format requirements. This primarily affects larger organisations with well-established data exchange relationships. We will clarify with you on a case-by-case basis whether a switch to an EN 16931-compliant format is necessary.
From 2028: Mandatory for all
From 1 January 2028 at the latest, the e-invoicing requirement will apply to all businesses in the domestic B2B sector, regardless of turnover. Paper and PDF invoices will then only be permitted in the exceptional cases specified by law.
Why the second transition period (1 January 2028) is hardly feasible for outgoing invoices – and why you should definitely start sending e-invoices from 1 January 2027
The extension until the end of 2027 for issuers with a turnover of up to 800,000 euros does exist in law. In practice, however, it can hardly be relied upon for outgoing invoices to businesses – due to a loophole on the recipient’s side.
Whoever receives an invoice bears the risk for their own input tax deduction. If your business customer receives a PDF invoice in 2027, its validity depends solely on your (as the supplier) turnover for the year 2026 – information that is not apparent from the invoice and which the recipient cannot verify.
If your turnover in 2026 was 800,000 euros or less, the PDF is valid and the recipient’s input tax deduction is not at risk. If your turnover exceeded this amount, an e-invoice should have been sent – and the recipient, who only has a PDF, risks losing their right to deduct input VAT.
If there is an obligation to issue an e-invoice but only another type of invoice is issued (for example, a PDF), the recipient is generally not entitled to claim input tax deduction. This can only be secured by means of objective evidence – an effort that many recipients wish to avoid.
From the recipient’s perspective, the simplest way to avoid this risk is to require an e-invoice from all suppliers – regardless of the supplier’s size.
For your outgoing invoices to businesses, this means that you would be better off not relying on the second transitional period. Anyone who continues to send PDFs risks receiving queries, delayed payments or requests to reissue the invoice as an e-invoice. We therefore recommend switching to e-invoicing at an early stage, ideally regardless of the €800,000 threshold.
Which invoices are not affected
Not every invoice needs to be issued as an e-invoice. The following, in particular, are exempt from this requirement:
- Invoices to private customers (B2C): The existing rules continue to apply to invoices issued to non-business customers.
- Small-value invoices up to 250 euros: Any format remains permissible here.
- Travel tickets: Tickets for passenger transport remain exempt.
- Certain tax-exempt transactions: There is no e-invoicing obligation for some services that are tax-exempt under the Value Added Tax Act.
- Small businesses (Section 19 of the VAT Act): Small businesses are not required to issue e-invoices for their own outgoing invoices – however, they must be able to receive them.
Which tax-exempt transactions are exempt
Exempt are certain VAT-exempt services under Section 4 Nos. 8 to 29 of the VAT Act (UStG), such as many financial and insurance services or certain letting transactions. Whether a specific service falls under this depends on the individual case – please contact us if in doubt.
How to prepare outgoing invoices
The switch to e-invoices for outgoing invoices can be tackled in just a few steps. Essentially, it comes down to ensuring that your invoicing software generates a valid format and that your master data is complete.
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Check your invoicing software
Check whether your invoicing or stock management programme can generate an XRechnung or a ZUGFeRD file. Many programmes now offer this as a standard feature or via an update.
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Choose a format
Decide whether to use XRechnung (pure XML) or ZUGFeRD, or Factur-X (PDF with embedded structured data). Both formats meet the requirements of the EN 16931 standard.
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You organise your master data
Check addresses, VAT registration numbers, service descriptions, service periods and bank details. E-invoices will be rejected if mandatory fields are missing or contain errors.
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You create a test invoice
You send a test invoice and have it checked to ensure that the structured file has been generated correctly and is read by the recipient.
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You switch over to sending e-invoices
From then on, you send live e-invoices to your business customers. Paper and PDF formats are no longer used for these invoices.
Frequently asked questions
Do I have to start sending e-invoices from 2025?
You have been required to receive e-invoices since 1 January 2025. You only need to switch to sending them once the transition periods have expired – from 2027 or 2028, depending on your turnover.
Does a PDF invoice count as an e-invoice?
No. For VAT purposes, a PDF is classified as a standard invoice. An e-invoice is only considered as such if the data is contained in a structured format such as XRechnung or ZUGFeRD, which can be processed automatically.
My turnover is below 800,000 euros – can I continue using PDFs until the end of 2027?
Legally, yes, with the recipient’s consent. In practice, however, from 2027 onwards many business customers will only accept e-invoices because they cannot verify your turnover and want to safeguard their input tax deduction. Switching over early will save you from having to deal with queries.
How does my business customer know whether I’m below the threshold?
Your turnover from the previous year isn’t apparent from the invoice itself. The recipient therefore cannot assess with certainty whether your PDF is valid – and so often requires an e-invoice from all suppliers as a precaution.
What happens to the input tax deduction if I receive a PDF?
As long as the transitional rules apply to the issuer, claiming input tax deduction from a PDF is generally not an issue. However, if an e-invoicing obligation is already in place and you only receive a PDF, the deduction is generally at risk. It can then only be secured by providing objective evidence.
Which formats are permitted?
Structured formats compliant with the EN 16931 standard are permitted. In Germany, XRechnung (pure XML) and ZUGFeRD or Factur-X (PDF with embedded data) are widely used.
Do the rules also apply to invoices sent to private customers?
No. The e-invoicing requirement applies only to invoices between domestic businesses (B2B). For invoices to private customers, the previous rules continue to apply.
What about invoices for small amounts?
Invoices up to 250 euros gross are exempt from the e-invoicing requirement. In these cases, you may continue to use paper or PDF.
I’m a small business owner – do I have to issue e-invoices?
You are not required to issue e-invoices for your own outgoing invoices under Section 19 of the German Value Added Tax Act (UStG). However, even as a small business owner, you must be able to receive e-invoices. You are, of course, free to send e-invoices on a voluntary basis.
When does the requirement apply without exception?
From 1 January 2028, all domestic businesses in the B2B sector must issue e-invoices, regardless of turnover. The only exceptions are those specified by law, such as invoices for small amounts or B2C invoices.
Legal notice
This article provides an overview and is not a substitute for individual advice. The legal situation and administrative interpretations may change; the current status at any given time applies. Our assessment of the practical significance of the second transition period is a professional evaluation of the market situation and does not constitute a statement on the legal position – legally, the deadline remains until the end of 2027.
If you have specific questions regarding your turnover threshold, the appropriate format or the exemptions, please contact us directly.
As at: June 2026