German e-invoice deadlines: 2025, 2027 and 2028

Receiving and issuing have different timelines

German domestic businesses have needed to be ready to receive e-invoices since 1 January 2025. Mandatory issuance follows a separate timetable, with transitions through the end of 2026 or, where conditions apply, 2027. Waiting until 2028 can therefore overlook a task that already exists: receiving suppliers’ structured invoices. The German tax authority explains receiving and issuing separately.

An e-invoice contains structured data that can be processed electronically. An ordinary PDF or scan does not meet that definition merely because somebody emails it. XRechnung and suitable ZUGFeRD/Factur-X profiles can carry structured invoice data; the particular format must meet the applicable requirements. See section 14(1) of the German VAT Act.

For a small business, the immediate practical step is to establish an incoming-file process, even when its own outgoing invoices still benefit from a transition.

The deadlines at a glance

This summary concerns domestic business-to-business transactions within the obligation’s scope. First check whether a statutory exception applies. The issuance transitions are set out in section 27(38) UStG.

The turnover test concerns the issuer. For the 2027 extension, look at that business’s turnover in calendar year 2026. Exactly €800,000 remains within the boundary. The turnover-threshold article explains this with examples.

Check the scope and exceptions

The starting point is a supply between businesses established in Germany, for the recipient’s business. Consumer sales and cross-border cases should not automatically be put into the same timetable. Invoices to public authorities also have their own requirements: confirm their format, references and submission channel separately. The B2B scope appears in section 14(2) UStG.

Issuance exceptions include specified VAT-exempt transactions, small-value invoices up to €250, passenger tickets and invoices for supplies exempt under the German Kleinunternehmer scheme. These are identified in the official tax-office overview. Saying that every business must issue every invoice electronically from 2028 would therefore be too broad.

An exemption for a Kleinunternehmer’s own invoices does not remove receiving duties. Read the separate small-business explanation before assuming that a small turnover means no preparation is necessary.

Prepare a workable invoice process

An email mailbox is generally sufficient as a receiving channel; other electronic methods are possible. The tax authority explains the available receiving arrangements. A workable business process also needs clear responsibilities:

1. Decide who retrieves incoming invoices and handles questions.
2. Keep the received original rather than passing on only a printout.
3. Read the data and compare the supplier, goods or services, and amounts with your records.
4. Investigate technical findings and request corrections from the issuer.
5. Test your own exports with the recipient and its intended submission channel before the deadline.

Passing technical validation does not establish that a supply happened or guarantee acceptance by a customer’s portal. Ask your tax adviser about the VAT treatment of unusual cases rather than trying to infer it from a validator’s result.

Next steps with FakturFokus

FakturFokus helps create and inspect supported invoice files. The public XRechnung check runs in the browser; always read its stated coverage. For hybrid PDFs, that browser check does not include complete PDF/A validation.

Start with choosing a format and the creation instructions. Arrange your own long-term retention process: FakturFokus provides temporary product storage, rather than an invoice archive. The retention article explains which originals to keep and how storage differs from checking a file.