Germany E-Invoicing 2027: Who Must Issue E-Invoices From January

Germany's e-invoicing rules for 2027 require every business whose total turnover in 2026 exceeded €800,000 to issue e-invoices for supplies to other businesses established in Germany from 1 January 2027. Businesses at or below €800,000 may keep using paper, or PDF with the customer's consent, for 2027 supplies. The legal basis is § 27(38) UStG.

This matters most to finance teams of mid-sized companies and German subsidiaries of international groups close to the threshold. The full timeline and permanent exemptions are in our guide to the Germany e-invoicing mandate; this article covers only 2027.

What changes on 1 January 2027?

The Growth Opportunities Act (Wachstumschancengesetz, Federal Law Gazette BGBl. 2024 I No. 108 of 27 March 2024) made e-invoices mandatory under Section 14 of the German VAT Act (§ 14 UStG) when both supplier and customer are established in Germany. Section 27(38) of the VAT Act (§ 27(38) UStG) postpones the issuing obligation in two stages. The first stage applies to everyone and ends on 31 December 2026. For supplies from 2027, only no. 2 of the provision remains. It says that an invoice for a supply made in 2027 may be sent on paper, or with the customer's consent in another electronic format such as PDF, until 31 December 2027, if the issuer's total turnover (Gesamtumsatz, § 19(2) UStG) in the previous calendar year was no more than €800,000. Three rules follow:

1. The threshold applies to the business issuing the invoice. The customer's size does not matter.
2. The reference year is calendar year 2026, not 2027.
3. The relief depends on the supply being made in 2027. A supply from 2026 is not covered.

The German Confederation of Skilled Crafts (ZDH) called on 22 June 2026 for the 2027 stage to be moved to 1 January 2028. As of 28 September 2026, the law is unchanged.

Does the 2027 rule apply to foreign companies?

Only when both parties are established in Germany. Under section 14.1(4) of the VAT Application Decree (Umsatzsteuer-Anwendungserlass, UStAE), as amended by the BMF letter of 15 October 2025, a business is established in Germany if it has its seat, its place of management or a VAT fixed establishment involved in the supply there. A German VAT registration alone is not on that list.

• A Dutch company without a German establishment invoicing a German customer: no German e-invoicing obligation.
• A German GmbH owned by a US group invoicing German customers: fully covered, based on the GmbH's own turnover or its VAT group.
• A German supplier invoicing a customer established only in France: no German obligation, but French rules may apply.

Invoices to German public authorities (B2G) follow separate procurement rules, usually XRechnung.

Who must issue e-invoices from 2027?

The table covers supplies to businesses established in Germany buying for their business.

The self-billing rule is easy to miss: a distributor that settles its sales agents' commissions by self-billing tests its own turnover. Above €800,000, those self-bills must be e-invoices from 2027, even if every agent is far below the threshold. If a service provider invoices on your behalf, your own turnover counts.

Do I have to switch in 2027? A five-question test

Work through the questions per customer group; the first answer that gives a result applies.

1. Are you and your customer both established in Germany, and does the customer buy for its business? No: no e-invoicing obligation, for example for consumers or customers abroad. Yes: go to question 2.
2. Does a permanent exemption apply? Small-amount invoice up to €250 gross (§ 33 UStDV), travel ticket (§ 34 UStDV), invoice from a small business (§ 34a UStDV), or a supply exempt under § 4 nos. 8 to 29 UStG, for which § 14(2) sentence 2 UStG requires no invoice. Yes: another invoice format is allowed. No: go to question 3.
3. When was the supply made? Before 1 January 2027: paper or PDF only if sent by 31 December 2026, otherwise e-invoice. In 2027: go to question 4.
4. Was your 2026 total turnover €800,000 or less? Yes: paper, or PDF with consent, allowed until 31 December 2027. No: go to question 5.
5. Do you invoice this customer via EDI? Yes: EDI with consent allowed until the end of 2027. No: e-invoice from 1 January 2027.

Our Kleinunternehmer calculator checks whether you qualify for the small-business exemption (€25,000 and €100,000 limits). It does not calculate the €800,000 threshold.

Which turnover counts for the €800,000 threshold?

The figure is not revenue from your profit and loss account. It is total turnover (Gesamtumsatz) under § 19(2) UStG: the sum of taxable supplies "calculated on the basis of consideration received", minus certain exempt supplies. In practice:

• It is net, because consideration excludes VAT (§ 10(1) UStG).
• Payments count in the year received, not by invoice date.
• Supplies exempt under § 4 no. 8(i), no. 9(b) and nos. 11 to 29 UStG are deducted, for example residential lettings (no. 12) or medical care (no. 14). Supplies under § 4 no. 8(a) to (h), no. 9(a) and no. 10 are deducted only if they are ancillary.
• Sales of fixed assets are left out.
• Exports and intra-EU supplies (§ 4 no. 1 UStG) are included, because § 19(2) does not deduct them.

Example 1: joinery business that sold a van

Muster Tischlerei GmbH issued invoices worth €825,000 net in 2026.

The business is below the threshold and may keep issuing paper or PDF invoices for 2027 supplies.

Example 2: wholesaler with residential property

Beispiel GmbH reports revenue of €860,000 for 2026.

The transition rule applies. The tenants (consumers) and the Swiss customer need no e-invoice anyway.

Example 3: VAT group above the threshold

Muster Holding GmbH is the controlling company (Organträger) of Muster Service GmbH.

Each company is below €800,000, but the group is above it. Both must issue e-invoices to business customers in Germany from 1 January 2027. Intra-group documents are internal accounting records, not invoices, under section 14.1(1) UStAE as amended in October 2025, so they need no e-invoice.

What stays the same in 2027?

• Every business established in Germany has had to be able to receive e-invoices since 1 January 2025. An existing email inbox is enough.
• XRechnung and ZUGFeRD from version 2.0.1, except the MINIMUM and BASIC WL profiles, remain accepted formats. See XRechnung vs ZUGFeRD for which suits your customers.
• Small-amount invoices up to €250, travel tickets and invoices from small businesses remain exempt in 2027 and 2028.
• Consumers and customers abroad are outside the obligation.

Sector details are in our guides on e-invoicing for freelancers and e-invoicing for tradespeople.

Timeline: which invoice for which supply?

The second row surprises many readers. No. 1 of the transition rule allows paper or PDF for 2026 supplies only until 31 December 2026, and no. 2 covers only 2027 supplies. A December supply invoiced in January falls under neither, even below €800,000. Invoice December work in December, or issue an e-invoice.

What to do before the end of 2026

1. Estimate your 2026 total turnover from your VAT returns so far, using the rules above. The final figure is only known after 31 December, so prepare anyway if you are close.
2. In a VAT group, add up the third-party turnover of all members.
3. Split your customer list into German businesses, consumers, customers abroad and public authorities.
4. Invoice December 2026 work by 31 December or issue e-invoices for it.
5. Check whether your software produces XRechnung or ZUGFeRD in the EN 16931 profile, and if not, ask the vendor when it will.
6. Below the threshold, keep recording customer consent to PDF invoices. It needs no set form and can be part of your terms (BMF letter of 15 October 2024, para. 63).

Our e-invoicing conversion checklist turns these steps into a template.

How to create and check e-invoices with docutools.pro

For single invoices and tests, the generator is enough; no account is needed.

1. Open the generator to create an XRechnung or ZUGFeRD invoice. In the "Company" step, enter invoice number, date, due date and seller and buyer details. For public authorities, the Leitweg-ID goes into "Buyer reference / Leitweg-ID".
2. Under "Items", add description, quantity and unit price. One VAT treatment per invoice is possible, for example 19 % or "§ 13b reverse charge".
3. Under "Generate & download", choose "ZUGFeRD PDF" (marked "Recommended") if your customer still wants a readable PDF, or "XRechnung XML" for public-sector portals. The data is sent to our server for this.
4. Check the mandatory details: the German invoice requirements checker runs in your browser. Select "XRechnung/ZUGFeRD XML", upload the XML and click "Auto-check XML". It always marks service date, exemption note and discounts as missing, so tick those by hand.
5. You can also run the XRechnung XML through the XRechnung validator against the KoSIT rules. The file is sent to our server; the free plan allows two uploads a day up to 500 KB. The result is "KoSIT-conformant / Valid XRechnung" or "Not KoSIT-conformant", with the list of errors and warnings.

The generator only creates invoice type 380, with no self-billing and no mixed VAT rates. For larger volumes, use the CSV batch mode in the Pro plan or invoicing software. More articles are on the e-invoicing mandate topic page.

Open questions

• Businesses founded in 2027 had no turnover in 2026. On the wording, "no more than €800,000" is met. The BMF letters of 15 October 2024 and 15 October 2025 do not address this case.
• Neither the law nor the two BMF letters say how a customer can tell whether a supplier is below the threshold. A written statement from the supplier on its 2026 turnover helps in practice, but no rule requires one.
• The ZDH's call of 22 June 2026 for a postponement has not been implemented. The law text is what counts.

Sources

• § 27 UStG, subsection 38 (transition rule, German) (opens in a new tab)
• § 19 UStG, subsection 2 (total turnover, German) (opens in a new tab)
• § 14 UStG (e-invoice and invoicing obligation, German) (opens in a new tab)
• BMF letter of 15 October 2025 on e-invoicing (German) (opens in a new tab), which refers to the transition rules in the BMF letter of 15 October 2024 (BStBl I p. 1320, paras. 62 to 65)
• Growth Opportunities Act, BGBl. 2024 I No. 108 (opens in a new tab)
• ZDH on e-invoicing and the requested postponement (German) (opens in a new tab)

Last reviewed: September 2026

This article is general information, not tax or legal advice.