# Germany E-Invoice Mandate 2027/2028: Timeline, €800k Threshold, and Format Rules - Date: 2026-01-19 - Reading time: 8 min read Germany B2B e-invoicing timeline: receive since 2025, issue from 2027 for issuers above €800,000 turnover, and a broad mandate by 2028. Includes the 2027 ## Article overview This article explains Germany E-Invoice Mandate 2027/2028: Timeline, €800k Threshold, and Format Rules as a practical reference for European e-invoicing. It defines the topic in plain language, places it in the compliance context, and connects the explanation to invoice formats such as XRechnung, ZUGFeRD/Factur-X, UBL, and CII. ## Germany's B2B E-Invoice Mandate: Timeline, Thresholds, and Compliant Formats Germany is introducing mandatory B2B e-invoicing in stages. Domestic business-to-business transactions are moving to structured formats that meet the European EN 16931 standard, with statutory transition periods. This guide covers the reception requirement from 2025, the €800,000 turnover threshold for 2027, and the broader issuance requirement from 2028. ### Key Deadlines - **January 1, 2025:** All German businesses must be able to **receive** e-invoices (Active) - **January 1, 2027:** Issuers whose prior-year total turnover exceeds €800,000 must generally **issue** e-invoices for domestic B2B supplies - **January 1, 2028:** The remaining domestic B2B issuers must generally issue e-invoices, subject to statutory exceptions ### The Growth Opportunities Act (Wachstumschancengesetz) Germany's B2B e-invoicing rules were introduced through the **Wachstumschancengesetz** (Growth Opportunities Act) and implemented in the German VAT Act. For invoice teams, domestic B2B invoicing is moving from paper or plain PDF toward structured data that meets the statutory e-invoice definition. ### Detailed Timeline Breakdown #### Phase 1: Reception Capability (January 1, 2025) - Active Since January 1, 2025, domestic businesses must be able to receive e-invoices. An email inbox is sufficient for receipt, although the invoice itself must meet the statutory requirements. XRechnung and compliant ZUGFeRD/Factur-X are common EN 16931-based examples. #### Phase 2: Large Business Issuance Mandate (January 1, 2027) From January 1, 2027, issuers whose total turnover in 2026 exceeded **€800,000** must generally issue e-invoices for domestic B2B transactions. The statutory transition does not extend the option to use paper or plain PDF invoices for these issuers, unless another exception applies. #### Phase 3: Universal Issuance Mandate (January 1, 2028) From January 1, 2028, the remaining transition period expires. E-invoicing becomes the general rule for domestic B2B issuers, subject to statutory exceptions. Kleinunternehmer are exempt from the obligation to issue e-invoices, but they must still be able to receive them. ### 2027 Threshold Audit & Quarterly Action Plan Under § 27 Abs. 38 UStG, the **€800,000 threshold** is based on the issuer's total turnover (*Gesamtumsatz*) in the preceding calendar year (2026). In an Organschaft, the turnover of the entire VAT group is relevant. #### Quarterly Implementation Checklist for 2027 Readiness - **Q1 (Turnover and threshold check):** Confirm 2026 total turnover under § 19 UStG and whether the €800,000 threshold is exceeded. - **Q2 (Inbound Infrastructure):** Verify accounts payable (AP) software for receiving, parsing, and archiving EN 16931 XML files according to GoBD guidelines. - **Q3 (Outbound ERP / Converter Setup):** Upgrade billing systems or implement a PDF-to-ZUGFeRD/XRechnung converter pipeline for outbound invoices. - **Q4 (Testing & Validation):** Perform end-to-end testing and validation of BT fields (e.g. Leitweg-ID, VAT IDs, tax category codes) with key trading partners. ### Accepted E-Invoice Formats in Germany Format Type Best For **XRechnung** Pure XML B2G, automated processing **ZUGFeRD 2.x** Hybrid PDF/XML B2B, visual PDF + machine-readable XML **Factur-X** Hybrid PDF/XML Cross-border workflows; same hybrid standard family **Note:** Plain PDF emails without embedded XML are NOT compliant e-invoices. ### Exceptions and Special Rules Kleinunternehmer are exempt from issuing e-invoices, but they still need to be able to receive them. Other statutory exceptions include certain small-value invoices and specific exempt transactions. These exceptions are separate from the transition rules. ## How to use this guide Use the article as a starting point before changing a finance or ERP workflow: identify the applicable country rule or standard, decide which structured format is expected, validate the generated XML, and keep a documented exception process for invoices that require manual review. ## FAQ ### When is e-invoicing mandatory in Germany? Domestic businesses have needed to be able to receive e-invoices since January 1, 2025. Issuers above the €800,000 prior-year total-turnover threshold generally need to issue e-invoices from January 1, 2027; the general rule applies from January 1, 2028, subject to statutory exceptions. ### How is the €800,000 threshold calculated? The threshold is based on the issuer's total turnover (Gesamtumsatz under § 19 UStG) in calendar year 2026; in an Organschaft, the entire VAT group's turnover is relevant. ## Official references - [BMF E-Rechnung FAQ](https://www.bundesfinanzministerium.de/Content/DE/FAQ/e-rechnung.html) - [BMF guidance on mandatory e-invoicing (15 October 2025)](https://www.bundesfinanzministerium.de/Content/DE/Downloads/BMF_Schreiben/Steuerarten/Umsatzsteuer/Umsatzsteuer-Anwendungserlass/2025-10-15-einfuehrung-obligatorische-e-rechnung.pdf?__blob=publicationFile&v=5)