E-Invoicing From 2027: What Invoice Issuers Should Settle Before Year-End
On 1 January 2027, the transitional rule for issuing invoices ends for German companies with prior-year turnover above 800,000 euros. Why the current year's turnover decides, which invoices are affected, and what can still be prepared in the remaining months.
Since 1 January 2025, domestic companies in Germany have had to be able to receive e-invoices. For issuing invoices, a transitional rule under Section 27(38) of the German VAT Act applies: until 31 December 2026, all invoice issuers may still issue an “other invoice” instead of an e-invoice, meaning paper or an unstructured electronic format. At the turn of the year, this rule ends for a large share of companies.
Who the deadline affects
According to the Federal Ministry of Finance, the transition period is extended until the end of 2027 only for invoice issuers with prior-year turnover of up to 800,000 euros. For 2027, the relevant figure is therefore the turnover of 2026, the current year. Anyone above this threshold issues e-invoices from 1 January 2027. From 2028, the obligation applies to everyone.
This creates an awkward sequence: the final turnover figure is only known after the annual accounts are closed, but the obligation starts on the first day of the new year. Companies close to the threshold should therefore decide now on the basis of their forecast rather than wait for the accounts. Anyone clarifying the question with their tax adviser should also record the basis of calculation.
A second transitional rule concerns electronic data interchange. EDI procedures that do not already meet the requirements for an e-invoice may still be used until the end of 2027. That buys time, but it does not answer the question of what the data exchange should look like afterwards.
Which invoices are affected
The obligation covers invoices between domestic businesses. Invoices to consumers are not included. Small-amount invoices of up to 250 euros gross under Section 33 of the German VAT Implementing Ordinance are also exempt.
Only a structured format under the European standard EN 16931 counts as an e-invoice. In practice, that means XRechnung and ZUGFeRD from version 2.0.1, in each case excluding the MINIMUM and BASIC-WL profiles, which contain too little information. A PDF remains an “other invoice”, even when sent by email. The framework is set by the ministry’s guidance letters of 15 October 2024 and 15 October 2025.
What makes sense before December
A little over three months is not enough to rebuild invoicing from the ground up, but it is enough for the points that would otherwise lead to queries in January:
- Document whether you are in scope: turnover forecast for 2026, with the decision and its reasoning recorded in writing.
- Check outgoing invoices: does your system produce a compliant format, or only a PDF showing an invoice? Validation against the EN 16931 rules shows this quickly.
- Cover special cases: self-billing credit notes, instalment and final invoices, and corrections follow the same rules and are easily forgotten in testing.
- Test with your main customers: a few test invoices to your largest business customers show whether the transmission route and the format are actually processed on the receiving side.
- Clean up master data: missing or outdated details surface immediately in a structured format, because mandatory fields can no longer be papered over with free text.
Then there is retention. What counts is the structured data record, not the human-readable copy. Anyone who has so far archived only PDFs should make sure the original is stored in an audit-proof way from January.
For many companies, 1 January 2027 will come as no surprise. It becomes a surprise where the first rejected invoice is what reveals that the company’s own format does not hold up.