Germany goes e-invoicing on 1 January 2027: what it means for you

E-invoicing in Germany is usually reported as one deadline. It is three, and one of them is already behind us.

Since 1 January 2025 every business established in Germany has had to be able to receive structured e-invoices. No transition period, no exemption for small operations, none for the small business scheme. What arrives at the turn of 2027 is the obligation to issue them, staged by revenue.

This post sorts out the deadlines, explains what counts as an e-invoice and what does not, and then covers the part most guides skip: what has to change on your website and in your store.

We build websites and stores, we are not tax advisers. This post organises the rules and does not replace advice on your specific situation.

The three deadlines

The second row turns on total revenue in the preceding calendar year, set out in section 27 paragraph 38 of the German VAT Act. So 2027 is decided by revenue from 2026, the year we are in.

Below 800,000 euros in 2026, paper invoices stay permitted through 31 December 2027. Other electronic formats such as a PDF are also allowed during that window, but only with the recipient's agreement. Paper needs no agreement.

The same end-of-2027 date applies to existing EDI arrangements that do not yet meet the new requirements.

What counts as an e-invoice

This is where the common misunderstanding sits. An e-invoice is not an invoice that arrives by email.

Section 14 of the German VAT Act requires a document issued, transmitted and received "in a structured electronic format" that "allows electronic processing". It means data that software can read without retyping or recognising it.

ZUGFeRD is the most comfortable answer for most small operations. It is a PDF with the data embedded. A person sees the familiar invoice, the software on the other end reads the data part. The same document therefore works for business and consumer customers alike.

Retention still has one catch: the structured data is the original. A printout is not enough. The period is eight years, counted from the end of the calendar year in which the invoice was issued (section 14b of the VAT Act).

Who stays exempt

Not every invoice has to become an e-invoice, and the exemptions are broader than most people assume.

Two of those deserve emphasis.

The 250 euro line is a gross figure, tax included, and in retail it covers a great deal of activity. Anyone billing mostly small amounts is less affected in practice than the headlines suggest.

The small business scheme only exempts issuing. The receiving obligation has applied since 2025 to those businesses as well.

What it means for your website and your store

Most guides skip this part because they come from accounting. For anyone running a website or a store, concrete changes hang on it.

The store has to tell business customers from consumers

This is the important one and it gets missed. Whether an invoice must be an e-invoice depends on who is buying. If your checkout does not ask, you do not know.

In practice that means:

• a field for the company name at checkout
• a field for the VAT identification number, optional but a reliable signal
• logic that picks the invoice format from those fields

A store that treats every order alike will from 2027 either produce too few e-invoices or send consumers a file they cannot use.

The invoice your store produces is probably not one yet

The usual invoicing extensions produce a PDF. That is fine through the end of 2026 and after that only for consumers. Check in good time whether your extension can output ZUGFeRD or XRechnung and whether the version is current enough. We looked at one of the tools for this in a separate post.

An inbox for invoices, and it has to be findable

For receiving, the German finance ministry considers an email inbox sufficient. A dedicated one such as invoices@yourdomain.com is worth having for two reasons: the files do not get lost among enquiries, and retention has a clear source.

For suppliers to use it, it has to be findable. Good places are the contact page, the footer, and your own outgoing invoices.

An order confirmation is not an invoice

An order confirmation, a payment confirmation and an invoice are three different things. Many stores send the first two automatically and generate the invoice somewhere else entirely. Only what is actually issued as an invoice counts for the mandate.

What comes after Germany

Germany is early, and the rest of the EU follows. Under the EU's VAT in the Digital Age package, structured e-invoices and near real-time reporting become mandatory for cross-border intra-EU business transactions from 1 July 2030, again on the EN 16931 standard.

In other words, the format work you do for Germany carries over. It is the same standard the rest of the single market is moving to.

Checklist before year end

The last one is the most tedious and the most important. Without that distinction in the data, the format cannot be chosen automatically, and then somebody does it by hand.

Three stubborn misconceptions

"I am small, this does not concern me." On issuing that is permanently true for the small business scheme and true through 2027 for everyone else. On receiving it has been true for nobody since 2025.

"I already email PDF invoices." That is an electronic invoice in everyday language and not an e-invoice in the legal sense. The difference is the structured data part.

"This needs expensive software." Receiving needs an inbox. For issuing, many accounting and store systems already ship the formats, often at no extra charge. The work is in the configuration rather than the purchase.

If your store should recognise business customers and produce the right invoice by the turn of the year, drop us a line. We will look at what your store outputs today and tell you what is missing.

Sources

• German Federal Ministry of Finance: FAQ on e-invoicing
• Section 14 VAT Act, issuing invoices
• Section 27 VAT Act, transitional rules, paragraph 38
• Section 14b VAT Act, retention of invoices
• European Commission: VAT in the Digital Age
• European standard EN 16931