Germany's E-Invoicing Mandate: The 2025-2028 Timeline Nobody Reads Correctly
Germany's e-invoicing mandate has three dates, one threshold, and one trap. The trap: the 800,000 EUR threshold counts your total turnover, not your B2B revenue. Here is the timeline as the law states it.
Germany's E-Invoicing Mandate: The 2025-2028 Timeline Nobody Reads Correctly
Germany introduced mandatory B2B e-invoicing through the Wachstumschancengesetz (Growth Opportunities Act), which amended Section 14 of the VAT Act (UStG). The rollout has three dates. Most businesses get at least one of them wrong.
The Three Dates
| Date | Obligation | Who is affected |
|---|---|---|
| 1 January 2025 | Mandatory receipt capability | All businesses in Germany |
| 1 January 2027 | Mandatory issuance | Businesses with prior-year total turnover above 800,000 EUR |
| 1 January 2028 | Mandatory issuance | All remaining businesses |
1 January 2025: The receipt duty that is already live
Since 1 January 2025, every business in Germany must be capable of receiving structured e-invoices compliant with EN 16931. This is not a future obligation. It has been law for 18 months.
Receipt capability means: you have a technical channel (an email mailbox, a Peppol endpoint, a supplier portal) through which an EN 16931-compliant e-invoice can reach you, and you can process it. You cannot refuse a compliant e-invoice and demand paper. Paper has lost its legal priority.
1 January 2027: Issuance above 800,000 EUR
From 1 January 2027, businesses whose total turnover in the previous year exceeds 800,000 EUR must issue structured e-invoices for all domestic B2B transactions. The BMF confirmed in April 2026 that this date will not be postponed.
From this date, paper and plain PDF are no longer acceptable sending formats for this group. PDF remains legally valid for receiving: a buyer cannot be forced to refuse a PDF during the transition. But the mandated issuer cannot send one.
1 January 2028: Everyone
From 1 January 2028, the issuance obligation covers all remaining businesses regardless of size. Paper and plain PDF lose their validity for in-scope domestic B2B invoicing entirely.
The Threshold Trap
The 800,000 EUR threshold is the most misread element of the mandate. Three details decide whether you are in scope for 2027:
- Total turnover counts. The decisive figure is Gesamtumsatz within the meaning of Section 19 (2) UStG. That is your entire turnover: domestic, export, B2C, everything. Not just your B2B revenue. A business with 500,000 EUR in B2C sales and 400,000 EUR in B2B sales has a Gesamtumsatz of 900,000 EUR and is in scope for 2027.
- The reference year is the prior year. For the 2027 obligation, your 2026 turnover decides. You will know your status when your 2026 books close.
- The threshold applies year by year. Cross it once, and the obligation applies from the following 1 January.
What Counts as an E-Invoice
Only a structured electronic format compliant with EN 16931 that enables automated processing qualifies. In practice:
- XRechnung (UBL or CII syntax)
- ZUGFeRD version 2.0.1 or later, EN 16931 or Extended profile
These formats do not qualify:
- Plain PDF (a "sonstige Rechnung", an other-format invoice)
- Word documents, scans, email text
- ZUGFeRD Minimum or Basic-WL profiles (insufficient data content)
Scope Exclusions
The mandate covers domestic B2B transactions between businesses established in Germany. Out of scope:
- Cross-border transactions (intra-EU and international)
- B2C invoices to private consumers
- Small-value invoices under 250 EUR (Kleinbetragsrechnungen)
- Tickets (Fahrausweise)
- VAT-exempt supplies under Section 4 Nos. 8-29 UStG
- Kleinunternehmer under Section 19 UStG
No Central Portal
Unlike Poland's KSeF or Italy's SdI, Germany has no government clearance platform. Transmission happens via email, Peppol, EDI, or supplier portals, by agreement between the parties. The Federal Chamber of Tax Consultants (BStBK) explicitly warns that email should be treated as a stopgap: interception and manipulation risk, plus GDPR exposure. Platform solutions are the recommended end state.
A second stage is already signalled: a VAT reporting system on top of the e-invoice, expected around 2030, and the BMF's 26-point action plan of 16 July 2026 commits to real-time electronic VAT reporting. The format mandate is the foundation, not the end state.
What To Do Now
- Confirm receipt capability. If you have not actively configured an e-invoice receipt channel, you have been non-compliant since January 2025.
- Calculate your 2026 Gesamtumsatz. Total turnover, not B2B-only. This decides your 2027 status.
- Check your software. Over 85% of German SME accounting software already generates XRechnung 3.0 or ZUGFeRD 2.3, per a Bitkom survey from March 2026. Verify yours.
- Validate a sample invoice with the KoSIT validator before your go-live.
- Set your switchover date. The BMF recommends October 2026 at the latest for businesses above the threshold.
This material is information of a general nature and does not constitute legal or tax advice. For a specific situation, verify the current rules or consult a qualified adviser.