Germany 2027: who must issue e-⁠invoices from 1 January, and what the ERP has to produce

On 1 January 2027 the e-⁠invoice obligation in Germany takes its second step. An issuer whose total turnover in the previous year was above EUR 800,000 can no longer send paper or PDF invoices to other businesses in Germany. It has to send e-⁠invoices, apart from general exceptions such as invoices up to EUR 250, and an EDI procedure agreed with the buyer that may still be used until the end of 2027 [1]. Smaller issuers follow a year later. This note is for whoever owns the ERP or the finance process in a German company, or in a foreign group with a German entity. It covers what applies, what changes, who is in scope, which formats count, what the ERP must produce and keep, and what to test.

The dates come from the VAT Act (UStG) and are law. The letters and the FAQ of the Federal Ministry of Finance (BMF) set out how the tax administration reads that law. The FAQ we read is marked "as of March 2026" [1].

What already applies since 1 January 2025

Since 1 January 2025, every business in Germany has had to be able to receive e-⁠invoices, with no exceptions. Even a small business that does not have to issue them needs an email inbox for that [1].

The definition changed on the same day. Before 2025, a plain PDF sent by email counted as an electronic invoice. Since 1 January 2025, an e-⁠invoice is an invoice issued, transmitted and received in a structured electronic format that allows electronic processing. A plain PDF no longer qualifies. Paper and plain PDFs are now "other invoices" (sonstige Rechnungen) [1].

Issuing is where the change is still to come. Until 31 December 2026, any issuer may send an other invoice instead of an e-⁠invoice. Paper is always possible. A PDF by email needs the buyer's consent [1].

What changes with the e-⁠invoice obligation in Germany in 2027

The transitional rules are in § 27(38) UStG [2]. Each one depends on two dates: when the supply was made and when the invoice is sent (or, for the EDI rule, issued). Read together, they give this:

Supply made in	Issuer	May the invoice still be paper or a PDF?
2025 or 2026	Any issuer	Yes, if it is sent by 31 December 2026. A PDF needs the buyer's consent
2025 or 2026, invoice sent in 2027 or later	Any issuer	No, unless a general exception applies
2027	Previous-year total turnover up to EUR 800,000	Yes, if it is sent by 31 December 2027. A PDF needs the buyer's consent
2027	Previous-year total turnover above EUR 800,000	No. Only an EDI procedure that is not itself an e-⁠invoice may still be used, with the buyer's consent, until 31 December 2027
2028 onwards	Any issuer	No, apart from the exceptions listed under who is in scope

The same rules as a decision, for one invoice:

The threshold is total turnover (Gesamtumsatz) as § 19(2) UStG defines it [3]. That is a VAT figure: taxable supplies counted on the payments received, without certain exempt supplies and without sales of fixed assets. It is not simply the revenue line in your accounts. For a supply made in 2027 the previous calendar year is 2026, so ask your tax adviser for that figure now for each German entity, and whether a VAT group (Organschaft) changes which turnover counts.

Who is in scope

The duty is in § 14(2) UStG [4]. It covers an invoice for a supply to another business for its business, when both the supplier and the buyer are resident in Germany. Resident means that the seat, the management or a permanent establishment involved in the supply is in Germany.

For a group:

• A German subsidiary, such as a GmbH, has its seat in Germany. Its invoices to businesses in Germany are in scope.
• A foreign company with a German establishment that takes part in the supply is in scope for that supply.
• A foreign company that is only registered for VAT in Germany, with no fixed establishment there, is not resident. The BMF says it can state this on its invoice to explain why it sends no e-⁠invoice [1].

The BMF letter of 15 October 2025 adds that the rules also apply to self-billed invoices (Gutschriften), to reverse-charge supplies where both parties are resident in Germany, and to the special schemes for farmers, travel services and the margin scheme. They apply even when the buyer is a small business or makes only exempt supplies [5].

There are exceptions [1]. The rules only apply where the VAT Act requires an invoice at all, so supplies exempt under § 4 Nos. 8 to 29 UStG, such as exempt financial services and exempt letting, are outside them [1]. An invoice that also covers taxable supplies, or a supply that is taxable because the business opted to tax it, is back inside [5]. Where an invoice is required, it still does not have to be an e-⁠invoice for small amounts up to EUR 250 gross, for tickets that count as invoices, and for invoices from small businesses under the Kleinunternehmer scheme.

What counts as an e-⁠invoice

§ 14(1) UStG allows two kinds of structured format [4]. The first meets the European standard EN 16931 and its list of syntaxes. The second is agreed between issuer and buyer, as long as the required VAT details can be extracted correctly and completely into a format that meets the standard or works with it.

In practice, according to the BMF:

• XRechnung qualifies. It is a purely structured format, developed by KoSIT [1].
• ZUGFeRD qualifies from version 2.0.1, except the MINIMUM and BASIC-⁠WL profiles [1]. It is a hybrid invoice: a PDF a person can read, with the XML inside.
• Other formats that meet EN 16931 qualify too. The format does not have to be German, and which allowed format you use is for you and the buyer to agree [5].
• EDI formats such as EDIFACT can carry on as e-⁠invoices if the parties agree on them and the VAT details can be extracted as described above [1].
• A plain PDF or paper does not count [1].

Two points in the letter of 15 October 2025 matter for the ERP [5]. A file with format errors, one that does not match the allowed syntax, is not an e-⁠invoice. It is an other invoice. And every mandatory VAT detail has to sit in the structured part. A reference to an attachment that holds those details is not enough, and neither is a link to an external site.

In one table:

What you send	Is it an e-⁠invoice?	Note
XRechnung	Yes	Purely structured, developed by KoSIT
ZUGFeRD 2.0.1 or later	Yes, except the MINIMUM and BASIC-⁠WL profiles	A hybrid invoice. The XML counts
Another format that meets EN 16931	Yes	The issuer and the buyer agree on it
EDI such as EDIFACT	Yes, if the parties agree and the VAT details can be extracted	As described above
A file with format errors	No	It is an other invoice
A plain PDF or paper	No	It is an other invoice

What the ERP has to produce

An e-⁠invoice starts as data in your ERP. In Germany there is no central platform and the law sets no channel. Email, an interface, a download from a portal or another channel all work, and the parties agree it between them [1]. In Germany, the route in the diagram is that agreed channel.

▶Play

1. 01ERP export
2. 02Mapping
3. 03Validation
4. 04Route
5. 05Buyer and tax platform

↺Status comes back by webhook or API: accepted, rejected with a code, or refused by the buyer.

ERP exportERP data

Your ERP produces the invoice data: a report, a file or an API call.

What can go wrongA field is missing from the export, such as the buyer's VAT number.

The export has to carry the details § 14(4) UStG requires on every invoice [4]. Among them: both parties' names and addresses, the seller's tax number or VAT ID, the invoice date, a unique sequential number, the quantity and type of goods or the scope of the service, the date of supply, the net amount split by tax rate, and the tax rate with the tax amount, or a note on the exemption. In an e-⁠invoice all of them must be in the structured part [1].

A few details catch ERP teams out. They come from the BMF FAQ [1] and the letter of 15 October 2025 [5]:

• Where the duty applies, a correction must also be an e-⁠invoice, using the invoice type for a correction. During the transitional periods a correction may still be an other invoice.
• XRechnung requires the field BT-⁠10, the buyer reference [5]. Between businesses no Leitweg-ID is needed. For VAT purposes a placeholder such as "-" is enough. Whether the buyer assigns its own reference for this field is the buyer's internal decision, so use it if the buyer gives you one [1].
• An advance or down-payment invoice issued before your start date does not have to be an e-⁠invoice, even if delivery and payment come later.

The BMF does not make validation a legal condition, but it recommends validating when an invoice is created and sent. For reasons of equal treatment, it says it cannot recommend a particular validation tool. KoSIT publishes open-source components for XRechnung, including a validator and a test suite [1]. The letter of 15 October 2025 also warns that a validator will not catch every content error. A wrong tax rate can pass the business rules [5].

What the ERP has to keep

§ 14b UStG requires a copy of every invoice you issue, and every invoice you receive, to be kept for eight years from the end of the calendar year in which it was issued. Its origin, its integrity and its legibility must be assured for the whole period [6].

For an e-⁠invoice, at least the structured part must be kept unaltered in its original form. For VAT purposes, storing e-⁠invoices outside a GoBD-compliant system is, as a rule, not a breach in itself. For other purposes the BMF points to its GoBD letter of 28 November 2019, last amended on 14 July 2025 [1].

Keep the validation report too. The letter of 15 October 2025 says a business that takes due care may rely on the technical result of a suitable validator for format and business rules, and suggests keeping the report as evidence [5]. For the ERP this means one thing: the record is the file you sent. A PDF printed from the ERP later is not.

What to test before January

1. Get the 2026 total turnover figure from your tax adviser for each German entity, ask whether a VAT group (Organschaft) changes it, and decide which date applies.
2. List every document that leaves the ERP for a business in Germany: invoices, corrections, self-billed invoices, advance invoices, and the unusual ones such as reverse-charge lines.
3. Ask your main buyers which format and channel they expect: XRechnung in UBL or CII, or ZUGFeRD and in which profile, by email or through another channel.
4. Generate a test file for every variant and validate it. Keep every report.
5. For ZUGFeRD, compare the PDF with the XML: same amounts, same VAT, same lines.
6. Check that the archive stores the file you sent, unaltered, with its report, for eight years.
7. Plan the January invoice run for December deliveries.

Where EurInvoice fits

We map ERP invoice data to XRechnung, in UBL or CII, or to ZUGFeRD. We validate each file against EN 16931 and the rules of the chosen format, check ZUGFeRD files as PDF/A-⁠3 with the XML inside, and hand back the validated file and its validation result for the channel you agreed with the buyer. There is no government platform to connect to in Germany, so the scope names the format, the profile, the buyer's requirement and the channel instead. The Germany page sets out what is ours and what stays with your team.

Our evidence for Germany is on the evidence page. XRechnung and ZUGFeRD invoices and credit notes, built from sample data with fictitious companies, were checked with the KoSIT validator, veraPDF and Mustang. They were accepted without messages, and the PDFs were valid as PDF/A-⁠3B. These are tests, not production traffic.

The standard unit covers one legal entity, one source system and one country route; inbound flows, archiving and ERP interface work are quoted separately. How it works shows the six steps.

What to do next

If an entity's 2026 total turnover is above EUR 800,000, its first invoice run of 2027 is the deadline. For every issuer, invoices sent in 2027 for December 2026 deliveries are outside the transition and have to be e-⁠invoices, unless a general exception applies. Send us one German case: a few representative invoices, the format and channel your buyers want, and the ERP they come from. We will tell you whether it fits the standard unit.