Whose turnover counts?
The €800,000 threshold determines access to an extended transition for issuing invoices in 2027. It concerns the invoice issuer’s total turnover in the preceding calendar year: 2026. Neither the customer’s turnover nor the amount of an individual invoice determines this test. The precise provision is section 27(38), point 2, UStG.
First establish that the transaction falls within the domestic B2B issuance obligation and that no exemption applies. The threshold is not a VAT rate or a new invoice category. Its purpose is to determine whether the issuer can still use this particular transition.
“Total turnover” is a statutory concept referring to section 19(2) UStG. Do not substitute bank receipts or an arbitrary dashboard figure without checking the basis. The relevant turnover is defined in section 19 UStG. Where your accounts include unusual transactions, ask your tax adviser to establish the correct figure before making the decision.
Three examples around the threshold
These fictional examples assume a domestic B2B transaction performed in 2027 that would otherwise fall within the obligation. Specific exemptions and the separate EDI provision are left out of the table.
| Total turnover in 2026 | Effect on the turnover-based transition |
|---|---|
| €799,999 | The threshold is not exceeded; the transition can apply. |
| €800,000 | Exactly at the boundary; the transition can still apply. |
| €800,001 | The threshold is exceeded; this transition does not apply. |
The wording means no more than €800,000, rather than less than that amount. A large supplier invoicing a small customer cannot use the customer’s lower turnover. Equally, selling to a large customer does not change the small supplier’s own previous-year turnover. Both examples follow the statute’s explicit reference to the issuer.
Consent and the EDI exception
Where the transition applies, paper or another electronic format may still be used for the relevant transactions through 31 December 2027. An ordinary electronic format, such as a simple PDF, requires the recipient’s consent. This permission does not turn the PDF into a structured e-invoice. See the conditions in section 27(38) UStG.
Point 3 separately permits certain EDI transmissions through the end of 2027, also subject to consent. That provision does not depend on the same turnover threshold. However, emailing an XML file does not by itself establish an EDI arrangement within that rule. Review the actual agreement and transmission method when assessing an existing EDI process.
These transitions concern issuance. They do not postpone the receiving readiness required since 2025. The deadline overview puts the two timelines side by side.
What changes in 2028?
From 2028, the transitions described here end for transactions within the obligation’s scope. Statutory exceptions continue. In particular, the German Kleinunternehmer scheme is not another name for the €800,000 transition. The tax authority lists the separate exemptions.
Ask two questions in order: does this transaction fall within the issuance obligation at all, and, if so, can the issuer use a transition in 2027? The small-business article explains the distinction for businesses making supplies exempt under section 19 UStG.
Prepare and check your invoice files
Even with time remaining, test a typical customer’s workflow early. Confirm the format and references, create a sample without real customer details, and verify the intended submission channel.
FakturFokus can create supported formats and explain technical findings. Start with the creation instructions or the public XRechnung check. The latter runs in your browser and states its coverage. Passing it does not determine your statutory turnover or guarantee recipient acceptance. The format guide helps you compare XML with a hybrid PDF before choosing the appropriate export.