E-invoice mandate: which deadline applies to which business

The e-invoice mandate doesn't arrive all at once but in stages. The most frequent question in our initial calls is therefore: when does it affect my business concretely? The answer hinges mainly on one figure: prior-year revenue. This article explains the deadlines and is expressly not legal or tax advice.

E-invoice deadline: which stage for which business

All domestic companies must receive an e-invoice from January 1, 2025 onwards. Businesses with prior-year revenue exceeding 800,000 euros must issue from January 1, 2027; all other businesses must by January 1, 2028 (per German Federal Ministry of Finance, e-invoice FAQ, as of 2026). Until each deadline, transition rules apply where paper and PDF invoices remain permitted. So the receipt mandate is already here; issuance requirements are being phased in.

Since 2025: everyone must receive

In the B2B area, any business receiving invoices must from January 1, 2025 be capable of accepting and processing a structured e-invoice. This stage has no revenue cap and no transition period. In practice, an email inbox and software that can read the format often suffice. A key point many underestimate: a business partner may now send you a genuine e-invoice, and you must accept it correctly, even if you yourself still issue paper or PDF.

E-invoice issuance by company size: 2027 or 2028

For issuance, company size determines the deadline, measured by taxable total revenue from the prior year. Between January 1, 2025 and December 31, 2026, all invoice issuers may continue sending regular invoices like paper or PDF. From January 1, 2027 onward, this freedom ends for companies with more than 800,000 euros revenue in 2026: they must then issue e-invoices. Businesses below that threshold get an extra year and may still send regular invoices through December 31, 2027 (per German Federal Ministry of Finance, §27 para. 38 German VAT Act). From January 1, 2028 the issuance requirement applies to everyone.

What matters is total company revenue, not profit, and not only B2B invoices. If you're close to or just above 800,000 euros in 2026, clarify the deadline early with your tax advisor, because it determines whether 2027 or 2028 is your trigger date.

What counts: XRechnung, ZUGFeRD, and the EN 16931 standard

An e-invoice under law is a structured dataset that software can automatically read and process. Permissible are formats under the European standard EN 16931, in Germany mainly XRechnung and ZUGFeRD from version 2.0.1 (excluding MINIMUM and BASIC-WL profiles). ZUGFeRD combines a structured data section with a readable PDF view, while XRechnung is pure XML. Importantly: a simple PDF emailed does not fall under this definition because it lacks the structured, machine-readable format (per German Federal Ministry of Finance). A scanned or printed PDF cannot therefore meet the issuance requirement from the relevant deadline onward.

Where automation applies

The real effort usually isn't the invoice format itself but the work before and after. Incoming e-invoices must be recognized, checked, assigned, and transferred to accounting; outgoing invoices must be generated in the right format and routed to the proper channel. Precisely these recurring steps can be automated so your team handles only exceptions, not every invoice by hand.

We've described how to automate invoice receipt concretely, from reading to approval, in the article Processing invoices automatically. For format-compliant conversion of in- and outbound, we've consolidated the topic on our page for E-invoice automation.

Control stays with you

Automation doesn't mean a black box runs your invoices. We set up in- and outbound so every step stays traceable: you see which invoice was checked and handed off when, and you retain approval authority where it belongs. Format validation, assignment, and handoff to accounting happen behind the scenes; the final call in case of doubt stays with your team.

Whether the switch is worth it for your business and where it saves the most time is best explored with your concrete process. An overview of how we generally automate workflows is on our page for Process automation.

Common questions

When does the e-invoice requirement apply to my business?

You must be able to receive an e-invoice from January 1, 2025. You must issue from January 1, 2027 if your total revenue in 2026 exceeded 800,000 euros, otherwise from January 1, 2028 (per German Federal Ministry of Finance). Until each deadline, paper and PDF invoices remain allowed.

Is a PDF invoice an e-invoice?

No. A simple PDF emailed doesn't count as an e-invoice per the German Federal Ministry of Finance, because it lacks the structured, machine-readable format. An e-invoice under law is a dataset per the EN 16931 standard, such as XRechnung or ZUGFeRD from version 2.0.1 onward.

What revenue determines whether it's 2027 or 2028?

It's your company's total taxable revenue in 2026, not profit and not just B2B sales. If it exceeds 800,000 euros, 2027 is your deadline; if not, 2028. Edge cases warrant a conversation with your tax advisor.

Which formats are permitted for e-invoices?

Formats under the European EN 16931 standard are permitted. In Germany, that's mainly XRechnung and ZUGFeRD from version 2.0.1, except for MINIMUM and BASIC-WL profiles. XRechnung is pure XML; ZUGFeRD combines the dataset with a readable PDF view.

Do I have to replace my entire invoicing system?

Usually not. Many accounting and inventory systems already support the formats or will receive an update. Often it suffices to connect in- and outbound in format-compliant ways and automate the handoff, rather than switching the whole software.