German e-invoicing mandate 2027: What the self-employed need to know
German e-invoicing mandate 2027: from January 2027 firms above 800,000 euros prior-year turnover must issue e-invoices, from 2028 all. What it means for receipts.
In short: Since 2025 every business in Germany must be able to receive e-invoices. From 1 January 2027, businesses with a total prior-year turnover above 800,000 euros must issue e-invoices for supplies to other businesses, and from 1 January 2028 all businesses must. Small-amount invoices up to 250 euros, travel tickets and invoices from small businesses under § 19 UStG stay exempt, as do invoices to private customers.
Germany is introducing the e-invoice (E-Rechnung) in stages, and 2027 is the year it becomes real for many businesses. This does not mean a PDF sent by email, but an invoice in a structured, machine-readable format. If you write invoices you need to switch your software; if you receive them you need to file them correctly.
This article explains who is affected from when, which formats apply, which exceptions exist and what the change means for your receipts and their retention.
When does the e-invoicing mandate apply?
The mandate applies in three stages, set out in § 14 and § 27 para. 38 of the German VAT Act (UStG). What counts is the date of the supply, not the invoice date.
| Period | Receiving | Issuing |
|---|---|---|
| 1 January 2025 to 31 December 2026 | mandatory for all businesses | paper and PDF still allowed (PDF with consent) |
| 1 January to 31 December 2027 | mandatory for all | mandatory above 800,000 euros prior-year turnover |
| from 1 January 2028 | mandatory for all | mandatory for all businesses |
For the 800,000-euro threshold, the total turnover of the previous year counts, so for 2027 it is your 2026 turnover. If you are below it, you may continue to issue paper invoices in 2027, or PDF invoices with the recipient's consent. From 2028 this transitional rule falls away.
Only invoices between businesses established in Germany (B2B) are affected. Invoices to private persons (B2C) are not covered by the mandate.
What is an e-invoice and what is not?
An e-invoice is an invoice in a structured electronic format under the European standard EN 16931 that allows automatic processing. Typical formats are XRechnung and ZUGFeRD from version 2.0.1.
What does not count as an e-invoice:
- a PDF, even if it is sent electronically
- a scanned paper invoice or a photo of one
- ZUGFeRD in the MINIMUM and BASIC-WL profiles, because they do not contain all mandatory details in structured form
For tax purposes a PDF is an "other invoice" (sonstige Rechnung). In its letter of 15 October 2025, the Federal Ministry of Finance also clarifies that a file with structural errors only counts as an other invoice. The ministry's e-invoicing FAQ is available at bundesfinanzministerium.de.
Which exceptions are there?
Three types of invoice may still be issued as paper or PDF after 2027. This applies permanently, not just during the transition.
- Small-amount invoices up to 250 euros gross (§ 33 UStDV). The fuel receipt, the restaurant bill and the hardware store till receipt stay as they are.
- Travel tickets (§ 34 UStDV), for example rail and public transport tickets.
- Invoices from small businesses under § 19 UStG (§ 34a UStDV).
Important: small businesses must still be able to receive e-invoices. An email inbox and a way to display the file in readable form are usually enough. What a small-amount invoice must contain is covered in Small-amount invoices up to 250 euros.
How do you keep e-invoices correctly?
With an e-invoice, the structured file is the original, and that is exactly what you must keep. Under § 14b UStG the period is 8 years, counted from the end of the calendar year. The file must stay unchanged and readable.
That leads to three practical rules:
- Save the XML file (or the ZUGFeRD PDF with embedded XML), not just a view or a printout.
- File e-invoices where your bookkeeping or your tax adviser processes them, ideally in a system that meets the GoBD.
- Name files so you can find them again, and back them up regularly.
How long which documents must be kept in Germany is explained in Retention periods in Germany. For scanned paper receipts, the rules on replacement scanning also apply; see GoBD and replacement scanning.
Do you still need a receipt app after 2027?
Yes, for everything that does not arrive as an e-invoice, and that is still a lot. Till receipts, small-amount invoices up to 250 euros, travel tickets, invoices from small businesses, receipts from abroad and slips on thermal paper are not covered by the mandate and keep landing in your hand on paper or as a photo.
These are exactly the receipts that get lost most easily and fade fastest. With Belego you photograph them right after the purchase; the app saves them as PDFs and reads the amount, date, merchant and category, and on request VAT rate, VAT amount and payment method too. At the end of the month or year you export everything as a ZIP with PDFs and a CSV list, or as a PDF report for your tax adviser.
An e-invoice in XML format, however, does not belong in a receipt app but directly in your accounting software or with your tax adviser. Belego does not process XML files. The sensible split is therefore: e-invoices flow digitally into your bookkeeping, and paper receipts and small amounts are collected with the app. How to hand both over so your tax adviser can work quickly is covered in Handing receipts to your tax adviser.
Note: This article is general guidance, not tax advice. What counts is the law, the letters of the Federal Ministry of Finance and the information from your tax office or tax adviser.
Frequently asked questions
Does the 2027 e-invoicing mandate apply to small businesses?
Not for issuing. Small businesses under § 19 UStG may permanently write their invoices on paper or as PDF (§ 34a UStDV). But they have had to be able to receive e-invoices since 1 January 2025, for example via an email inbox. When an e-invoice arrives, the XML file must be kept.
Does the 800,000-euro threshold refer to 2026 or 2027 turnover?
The total turnover of the previous year counts. For supplies in 2027 you look at your 2026 turnover. If it was at most 800,000 euros, you may still issue paper or PDF invoices in 2027, the PDF with the recipient's consent. From 1 January 2028 the mandate applies regardless of turnover.
Is a PDF by email still allowed from 2027?
For businesses above the 800,000-euro threshold only in the exceptions, meaning small-amount invoices up to 250 euros and travel tickets. Businesses below the threshold may keep sending PDFs in 2027 with the recipient's consent. From 2028 a PDF is only allowed for the exceptions in B2B, while invoices to private customers remain unrestricted.
Does the German mandate affect Swiss companies?
The mandate applies to supplies between businesses established in Germany. A Swiss company without a registered office or permanent establishment in Germany is generally not obliged to issue e-invoices under German law. If you are registered for VAT in Germany or have a permanent establishment there, check your situation with a tax adviser.