Tysklands krav på e-faktura: berörs du, och är din faktura giltig?

Am I affected?

1. Is your total turnover in 2026 above €800,000? For the 2027 mandate the previous year's total turnover counts, i.e. 2026, computed on payments received (§ 19 (2) UStG); in a VAT group the whole group counts.
2. Do you invoice companies or public bodies in Germany? Invoices to consumers (B2C) and to recipients abroad are not covered by the mandate.
3. Are you a small business (Kleinunternehmer) under § 19 UStG? Small business: at most €25,000 turnover in the previous year and €100,000 in the current year, no VAT on the invoices.
4. Do you receive invoices from companies in Germany? For example from suppliers, landlords, service providers or your tax adviser.

Receiving:

Mandatory for you too since 1 January 2025: every business established in Germany must be able to receive e-invoices, small businesses and landlords included. An email inbox is enough (BMF letter of 15 Oct 2024, paras. 40 and 62).

Issuing:

Mandatory from 1 January 2027 for supplies from that day, because your total turnover in 2026 is above €800,000 (§ 27 (38) no. 2 UStG; BMF letter of 15 Oct 2024, paras. 63–65). Until the end of 2026 paper and, with the customer's consent, PDF invoices are still allowed.

Mandatory from 1 January 2028. With at most €800,000 total turnover in 2026 you may still send paper and, with the customer's consent, PDF invoices for supplies in 2027 (§ 27 (38) no. 2 UStG).

Not mandatory, not even from 2028: small businesses may always send paper or PDF invoices (§ 34a UStDV; BMF letter of 15 Oct 2025, para. 22). You must still be able to receive e-invoices.

Not mandatory for your current invoices: invoices to consumers and to recipients abroad are exempt. Once you invoice companies in Germany, the mandate applies from 2027 (previous-year total turnover above €800,000) or from 2028.

Always exempt: small-amount invoices up to €250 in total, travel tickets, invoices to consumers or abroad, and turnover exempt under § 4 nos. 8 to 29 UStG such as residential letting or medical treatment (§§ 33, 34 UStDV). Formats under EN 16931 count as e-invoices, i.e. XRechnung and ZUGFeRD from version 2.0.1 except the MINIMUM and BASIC WL profiles; a plain PDF is an “other invoice”.

What is at stake? Not a fine (BMF letter of 15 Oct 2026, para. 28). But whoever owes an e-invoice and sends another invoice instead does not issue a proper invoice: your customer may not deduct input VAT from it (BMF letter of 15 Oct 2024, para. 56) until an e-invoice follows.

Sources: § 14 and § 27 (38) UStG (Growth Opportunities Act), §§ 33, 34 and 34a UStDV, the BMF letters of 15 Oct 2024 (BMF-Schreiben vom 15.10.2024, paras. 40, 56, 62–65), 15 Oct 2025 (paras. 22, 35a) and 15 Oct 2026 (para. 28). This assessment is not tax advice.

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