Guide · 2026-11-07
Markdown exportE-invoicing 2027: what accountants can recommend to clients without e-invoice software
From 1 January 2027, German businesses with prior-year total turnover above EUR 800,000 must issue e-invoices. From 2028 the obligation applies in principle to all domestic businesses in B2B trade. This guide shows tax advisers and bookkeepers which clients are affected and which options clients without suitable software have.
What changes for clients
Many clients write invoices in Word, Excel or an older program and send them as PDF files. From 2027 this is no longer enough for some clients when they invoice other businesses.
Since 1 January 2025, businesses in Germany must generally invoice supplies to other domestic businesses with an e-invoice. A plain PDF is not an e-invoice. Under the law it is a sonstige Rechnung (other invoice). The transition rules in § 27(38) UStG still allow a sonstige Rechnung for a limited time. Separate rules also apply to invoices to public authorities, for example the federal E-Invoicing Ordinance (ERechV) since 27 November 2020.
The information in this guide is as of 7 November 2026. It is based on § 14 and § 27(38) UStG, the e-invoicing FAQ of the German Federal Ministry of Finance (BMF, as of 29 October 2026), the BMF letter of 15 October 2024 (BStBl I S. 1320) and the BMF letters of 15 October 2025 and 15 October 2026.
Which clients must issue e-invoices from when
| Period | Who | What applies |
|---|---|---|
| Since 1 January 2025 | All domestic businesses | They must be able to receive e-invoices. An email inbox is enough for this. |
| Supplies in 2025 and 2026 | All issuers | A paper invoice is allowed. Another electronic format such as PDF is allowed if the recipient agrees. This applies only to invoices that the issuer sends by 31 December 2026. |
| Supplies in 2027 | Total turnover in 2026 above EUR 800,000 | An e-invoice is required unless an exception applies. An EDI procedure remains allowed until 31 December 2027 if the recipient agrees. |
| Supplies in 2027 | Total turnover in 2026 up to EUR 800,000 | Paper, or another electronic format if the recipient agrees, remains allowed. This applies only to invoices that the issuer sends by 31 December 2027. |
| Supplies from 1 January 2028 | All domestic businesses in B2B trade | An e-invoice is required unless a statutory exception applies. |
Interactive check
Does the German e-invoice mandate apply to you?
Set your 2026 turnover and situation. The grid shows what you must do each year.
Your situation
You must issue e-invoices from 1 Jan 2027. Your 2026 turnover is above €800,000, so the transition ends a year early for you.
How to check the EUR 800,000 threshold
The threshold uses the issuer's total turnover (Gesamtumsatz) under § 19(2) UStG in the preceding calendar year. For supplies in 2027, the total turnover of 2026 counts. According to the BMF letter of 15 October 2024 (para. 64), for a VAT group (Organschaft) the turnover of the whole group counts. For a self-billed invoice (Gutschrift), the total turnover of the business that issues it counts. If a third party such as an accounting firm issues the invoice, the client's total turnover counts.
By the wording of § 27(38) no. 1 UStG and the BMF letter of 15 October 2024 (paras. 63 and 64), the transition rule covers supplies from 2025 and 2026 only for invoices that the issuer sends by 31 December 2026. No. 2 covers only supplies from 1 January 2027. If a client invoices a 2026 supply only in 2027, that invoice must therefore be an e-invoice unless an exception applies. This also applies if the total turnover is EUR 800,000 or less. The same applies to 2027 supplies that a client invoices only in 2028.
The obligation also affects your clients' customers. If an issuer must issue an e-invoice and issues a sonstige Rechnung instead, that invoice in principle does not entitle the recipient to deduct input VAT. The BMF names exceptions, for example a correction by a later e-invoice.
When no e-invoice is needed
The obligation applies only when VAT law requires an invoice. According to the BMF FAQ, no e-invoice is needed in these cases:
- Invoices to consumers (B2C).
- Many VAT-exempt supplies under § 4 no. 8 to 29 UStG, for example exempt letting of property.
- Small-amount invoices up to EUR 250 gross (§ 33 UStDV).
- Tickets that count as invoices (§ 34 UStDV).
- Supplies by small businesses under the Kleinunternehmer scheme (§ 34a UStDV). These businesses must still be able to receive e-invoices.
- Supplies to legal persons that are not businesses, for example many associations.
Which formats count as an e-invoice
| Format | Counts as an e-invoice | Note |
|---|---|---|
| XRechnung | Yes | The file is pure XML under EN 16931 with German rules. The recipient needs a program or a viewer to read it, for example the e-invoice viewer of the tax administration at www.e-rechnung.elster.de. |
| ZUGFeRD from version 2.0.1, except MINIMUM and BASIC-WL | Yes | The file is a PDF with embedded XML. If the XML and the PDF differ, the XML data prevails. |
| ZUGFeRD in the MINIMUM or BASIC-WL profile | No | The BMF explicitly excludes these profiles. The file then counts as a sonstige Rechnung. |
| Other formats under EN 16931 | Yes | Examples are UBL or CII invoices under EN 16931. Issuer and recipient agree which permitted format they use. |
| EDI procedures | By agreement | The format must allow a correct and complete extraction of the mandatory invoice details into a format that meets EN 16931 or is interoperable with it (§ 14(1) sentence 7 UStG). |
| PDF by email or paper | No | This is a sonstige Rechnung. It is allowed only under the transition rules or an exception. |
Options for clients without e-invoice software
| Option | Suits | What clients must check |
|---|---|---|
| Update or replace the billing software | Clients with many or recurring invoices. | Ask the vendor whether the program creates a permitted format, for example XRechnung or ZUGFeRD in the EN 16931 profile. |
| Convert the PDF into an e-invoice | Clients who keep their current program and write few invoices. | The client reviews the recognized data of each invoice before the download. |
| Create the XRechnung in a form | Single invoices without a finished PDF. | The client types in all details by hand. With many lines this takes time. |
How Invoice Converter fits these options
The converter reads a PDF invoice and creates XRechnung, ZUGFeRD, Factur-X, UBL or CII from it. The client reviews the recognized data before downloading the file.
In the "Review Data" step, the client sees every recognized field and corrects it where needed. Poor scans and unusual layouts often need corrections. Special tax cases such as reverse charge always need a careful review.
Before the download, the service validates the file, for XRechnung with the KoSIT validator. Errors block the download of the final file. A passed validation shows that the file meets the format and the rules of the standard. It does not show that amounts, service and VAT rate match the original invoice. The BMF recommends that issuers validate an e-invoice when they create and send it.
For ZUGFeRD, the converter creates the EN 16931 profile by default. The client can also select the EXTENDED or XRechnung profile. The converter does not offer MINIMUM or BASIC-WL.
The service creates the file. It does not send it. The client sends the e-invoice to the customer, for example by email.
Costs for clients
| Service | Price |
|---|---|
| Upload a PDF and review the recognized data | Free |
| Download of a converted e-invoice | €5 excl. taxes per conversion, or use a subscription |
| Subscription | From €10/month excl. taxes with annual billing |
| Create an XRechnung in the form, with an account | Free, unless the invoice matches a conversion from the last 180 days. Then the download costs the same as a conversion. |
Limits when you work for several clients
Each account has exactly one set of seller master data. There are currently no workspaces for several clients.
The service bills all conversions of an account to that account. For clients with recurring invoices, a separate account with their own master data is often simpler.
Under VAT law, a third party such as an accounting firm can issue invoices in the name and on behalf of a client (§ 14(2) sentence 7 UStG). The client must then make sure that the third party meets the formal requirements of §§ 14 and 14a UStG (section 14.1(3) sentence 8 UStAE).
Switch off master data for every client invoice
If you convert invoices of several clients with one account, open "Advanced options" before each conversion and clear "Use seller master data from your profile". Otherwise every saved value replaces the recognized seller or payment value of the client. In the profile, "Use saved seller data automatically" sets whether this is on by default. Email imports on the Enterprise plan always follow this profile setting. If you have saved no seller master data, you can skip this step.
Checklist for client advice
- Determine each client's total turnover for 2026 under § 19(2) UStG, for a VAT group (Organschaft) the turnover of the whole group, and record whether it is above EUR 800,000.
- Check whether an exception applies, for example for Kleinunternehmer, small-amount invoices or invoices to consumers.
- Find out whether the client's billing program creates XRechnung or ZUGFeRD in a permitted profile.
- Ask the client to check format, buyer reference and delivery channel with important customers. An XRechnung needs the buyer reference (BT-10) under rule BR-DE-15.
- Ask the client to create, review and send a test invoice to a customer before the deadline.
- Decide who handles rejected invoices.
- Make sure that clients issue invoices for 2026 supplies that they send only in 2027 as e-invoices, unless an exception applies.
- Remind clients to keep invoices for eight years. For an e-invoice, the structured part must stay unchanged.
Questions from accountants
Is a PDF by email still enough from 2027?
For supplies in 2027, yes, if the client's total turnover in 2026 was at most EUR 800,000, the recipient agrees and the client sends the invoice by 31 December 2027. Regardless of turnover, a sonstige Rechnung stays allowed when an exception applies, for example a small-amount invoice up to EUR 250 gross. For supplies in 2026, by the wording of the law a PDF is enough only if the client sends the invoice by 31 December 2026. From 2028 a PDF is in principle no longer enough in B2B trade, unless an exception applies.
Does every ZUGFeRD file meet the obligation?
No. According to the BMF, ZUGFeRD files from version 2.0.1 meet the requirements, except in the MINIMUM and BASIC-WL profiles. Ask the vendor of the billing program which profile it creates.
Can a client create an XRechnung without software?
Yes. With an account, the client creates the XRechnung in the form under "Create XRechnung". This costs nothing unless the invoice matches a conversion from the last 180 days. Then the download costs the same as a conversion.
May the accounting firm create e-invoices for clients?
Under VAT law, yes. A third party can issue an invoice in the name and on behalf of the business (§ 14(2) sentence 7 UStG). The client remains responsible for making sure that the invoice meets the formal requirements. If you saved seller master data in your account, switch it off in the converter for each conversion. The seller details from the client's PDF then stay in the invoice.
Can I manage several clients in one account?
No. There is no client management. Each account has one set of seller master data and its own billing. Recommend a separate account to clients with recurring invoices.
Does Invoice Converter send the e-invoice to the customer?
No. The service creates and validates the file. The client sends it, for example by email. The law does not prescribe a specific delivery channel.
What about data protection for client invoices?
Invoices contain personal data. Read the data processing agreement under Art. 28 GDPR before the first upload. It lists the subprocessors and their locations.