Receiving is mandatory today, issuing is not.
Germany split the e-invoicing mandate in two. Since 1 January 2025 every business established in Germany must be able to receive a structured e-invoice, with no transition period and no exemption, not even for small businesses under the Kleinunternehmer rule. Issuing is the half that still has deadlines. A PDF sent by email no longer counts as an e-invoice at all: since 2025 it is a sonstige Rechnung, an ordinary invoice, and sending one in any electronic format needs the recipient's consent.
No fallback for those who cannot receive
The Ministry of Finance decree of 15 October 2025 is blunt about it: a business that is technically unable to receive an e-invoice, or refuses to accept one, has no claim to an alternative paper or PDF invoice from the issuer. The issuer's VAT duties count as fulfilled once he has issued the e-invoice and can demonstrate he tried to deliver it.
no claimThe formats are settled
Per the ministry's own FAQ, XRechnung and ZUGFeRD from version 2.0.1 (excluding the MINIMUM and BASIC-WL profiles) meet the VAT requirements. In a hybrid file the structured XML part now governs: if the picture and the data disagree, the data win.
EN 169312027 and 2028, decided by one number.
Section 27 (38) of the German VAT Act sets the transition. Until 31 December 2026 any issuer may still invoice on paper, or electronically in another format if the recipient agrees. That grace period runs one year longer, to 31 December 2027, only for issuers whose total turnover in the preceding calendar year did not exceed 800,000 euros. EDI that does not already meet the e-invoice definition also survives until the end of 2027. After that, issuing a proper e-invoice between domestic businesses is genuinely mandatory.
It hangs on the transaction, not the invoice date
Each numbered transition covers transactions carried out in a defined window, not invoices dated inside it. So the question for 2027 is your total turnover in 2026, and a late invoice for a 2026 job still follows the 2026 rules.
timingThe exemptions do not expire
Small-amount invoices up to 250 euros, transport tickets, invoices issued by Kleinunternehmer, invoices to private customers and many VAT-exempt supplies stay outside the issuing mandate permanently. 2028 removes the turnover threshold, not the exemptions.
permanentCheck the route, not the format.
Three ways lead to compliance and each has an honest limit. A converter solves the file and nothing else: the mandatory details have to sit in the structured part, and a converter reading a PDF is guessing. A vendor update is the right move when your system is current, but its date is set by the vendor's release calendar, and archiving is often a separate product. A rebuilt route costs the most and only pays off from a certain volume or with several source systems, and it is the only one of the three that also fixes what happens after dispatch: validation, matching, archiving, monitoring. We build that route and then operate it.