E-Invoice Mandate 2027: What Companies Need to Prepare Now

The Growth Opportunities Act (Wachstumschancengesetz) of March 27, 2024, has fundamentally restructured electronic invoicing in Germany. Starting January 1, 2027, a simple PDF invoice sent by email will no longer be sufficient for B2B transactions. Companies must send structured e-invoices complying with the European standard EN 16931 — specifically in ZUGFeRD or XRechnung format.

> Quick answer: From January 1, 2027, companies with prior-year revenue exceeding €800,000 must send B2B invoices as e-invoices (ZUGFeRD or XRechnung). From January 1, 2028, the mandate applies to all companies. The receiving obligation has been in effect since January 1, 2025.

What changes starting in 2027?

The mandate is being introduced in two phases:

The legal basis is § 14 UStG (German VAT Act) in its revised version. It defines the term "electronic invoice" more narrowly: only formats complying with EN 16931 qualify as e-invoices. A simple PDF is explicitly no longer an e-invoice under the law.

Why did the legislature introduce the e-invoice mandate?

The law serves two goals: first, combating VAT fraud through a planned digital reporting system (Transaction Based Reporting), and second, modernizing German SMEs. The EU is driving this development further through the ViDA initiative (VAT in the Digital Age) — EU-wide digital reporting is expected to become mandatory by 2030.

Who is affected by the sending obligation starting in 2027?

The sending obligation from 2027 applies to companies whose total revenue in calendar year 2026 exceeds €800,000. The decisive factor is prior-year revenue — not a forecast.

Affected:

• GmbHs, AGs, and other corporations with corresponding revenue
• Sole proprietors, freelancers, and partnerships with corresponding revenue
• All entities conducting taxable domestic B2B transactions

Not affected (until 2028):

• Companies with prior-year revenue up to €800,000
• Small businesses under § 19 UStG

From January 1, 2028, the sending obligation then applies to all companies without exception.

What qualifies as an e-invoice — and what doesn't?

The new legal definition is clear: an e-invoice must be in a structured electronic format that is machine-processable and complies with the European standard EN 16931.

Permitted formats:

• ZUGFeRD 2.x (from profile EN 16931 / COMFORT)
• XRechnung 3.0 (UBL 2.1 or CII)
• Factur-X (identical to ZUGFeRD)

No longer sufficient:

• Simple PDF files
• Scanned paper invoices
• Word or Excel documents sent by email

A PDF invoice can still be sent in addition — as a readable view for the recipient. However, only the structured XML is now legally relevant.

Should I use ZUGFeRD or XRechnung?

For most B2B scenarios, ZUGFeRD is the more practical choice:

• The file is a normal PDF with the XML invisibly embedded
• Recipients without e-invoicing software can simply open it
• Accounting software like DATEV, Lexware, and sevDesk reads it automatically

XRechnung is a pure XML file without a PDF wrapper. It is required when your client is a public sector entity, a Leitweg-ID is requested, or the document must be submitted via the ZRE.

What exceptions exist to the e-invoice mandate?

The sending obligation applies only to domestic B2B transactions. The following exceptions apply:

• Invoices under €250 (small-amount invoices per § 33 UStDV): still allowed in any format
• Small businesses under § 19 UStG: do not have to send e-invoices until 2028, but must still be able to receive them
• Transport tickets that serve as invoices: exempt
• Cross-border invoices (recipient abroad): not subject to the domestic B2B obligation

What does the e-invoice mandate mean specifically for your accounting?

Receiving e-invoices has been mandatory since January 2025 — your software should already support this. What's new is the sending obligation. For this, you need:

1. A tool that generates ZUGFeRD or XRechnung. Many ERP systems can already do this. For companies working with Word, Excel, or a simple invoicing tool, a supplement is necessary.

1. Correct master data. An EN 16931-compliant invoice requires mandatory fields such as the buyer's VAT ID, correct line item quantities and units. Incomplete master data leads to invalid e-invoices.

1. A validation step before sending. A rejected e-invoice delays payment. Check with the free ZUGFeRD & XRechnung Validator before sending.

How do I prepare my company step by step?

Now (2026):

• Check whether your 2026 annual revenue will exceed the €800,000 threshold
• Test whether your current software can generate ZUGFeRD or XRechnung
• Discuss the transition with your tax advisor

By end of 2026:

• Choose your output format (ZUGFeRD recommended for B2B)
• Ensure your VAT IDs and buyer master data are complete
• Validate a few test invoices before going live

From January 1, 2027:

• Send all outgoing B2B invoices only in e-invoice format
• Ensure an internal process for incoming e-invoices

What penalties apply for non-compliance with the e-invoice mandate?

The Federal Ministry of Finance has not yet published the sanctions in detail. What already applies: a non-compliant invoice may not be recognized for tax purposes, which jeopardizes the recipient's input tax deduction. You also risk delays if customers or government agencies reject invoices. Fines of up to €5,000 per violation are possible once tax authorities begin active enforcement.

Act now: Prepare for the 2027 e-invoice mandate

The 2027 e-invoice mandate is no longer a distant future — the deadline of January 1, 2027 applies to companies already generating more than €800,000 in revenue in 2026. Those who start preparing now will have sufficient time for a smooth transition.

TaxLayer automatically converts your existing PDF invoices into validated ZUGFeRD or XRechnung files. The first two conversions are free — no credit card required.