Mandatory e-invoicing from January 2027. Who has to send them and what your ERP should be able to do now

Until the end of 2026, you may still send invoices to other businesses on paper or as a PDF. From January 1, 2027, this only applies if your total turnover in 2026 was no more than €800,000. If it was higher, every invoice to a business in Germany has to be an e-invoice. From January 1, 2028, the obligation applies to everyone – regardless of turnover.

One thing is important here: an e-invoice is not simply an invoice sent by email. It is a file in a defined, structured format that software can read without retyping. Since 2025, a PDF invoice sent by email no longer counts as an e-invoice but as an “other invoice” (sonstige Rechnung).

Yes, if your total turnover in 2026 was more than €800,000. This means total turnover (Gesamtumsatz) under Section 19 (3) of the German VAT Act (Umsatzsteuergesetz, UStG) – not your turnover with individual customers. If you are below that, you have one more year: paper remains permitted until the end of 2027, other electronic formats such as PDF only with your customers' consent.

In principle, the obligation covers:

• invoices between businesses within Germany
• small businesses just the same, from 2028 at the latest
• every place where invoices are created: ERP, online shop, billing software

Exempt are, for example:

• small-amount invoices (Kleinbetragsrechnungen) up to €250
• tickets for passenger transport (Fahrausweise)
• certain tax-exempt supplies under Section 4 Nos. 8 to 29 UStG
• invoices to private customers

Permitted formats are those that comply with the European standard EN 16931. In practice, there are two:

• XRechnung: a pure XML file – made for software, readable for people only with a viewer.
• ZUGFeRD from version 2.0.1: a PDF with an embedded XML file. People read the PDF, software reads the XML.

Note: the ZUGFeRD profiles MINIMUM and BASIC-WL do not meet the standard. An invoice in these profiles is not an e-invoice – even if it looks like one.

If you invoice large customers via EDI, you may keep using a procedure that does not meet the standard until the end of 2027. After that, it has to meet the standard or be translatable into a suitable format.

E-invoicing is not a change of format – it is a master data project. The obligation applies where your invoices are created, and in most cases that is your ERP. Three things have to be right there:

1. The format. The system generates XRechnung or ZUGFeRD and checks the file before it goes out.
2. The master data. E-invoices require details that nobody missed on paper – typically the buyer reference, units as standardized codes and the seller's contact details are missing.
3. The delivery channel. Your customers receive the format they accept – by email or via a network such as Peppol.

In Business Central this is standard from version 26.3. The e-documents framework supports XRechnung, ZUGFeRD and Peppol BIS 3. You set up one e-document service per format and assign it to your customers via the document sending profile. A profile knows exactly one format. If you need different formats, you therefore need different profiles.

When receiving, Business Central reads all three formats and extracts the XML from a ZUGFeRD PDF itself. But that does not turn into a purchase invoice on its own. For that, the matching to vendors, items and purchase orders has to be set up.

Older versions and Dynamics NAV do not have this as standard. There you need an update or an extension. The integrations we build in Business Central are shown on our page Business Central integrations.

Example 1: A wholesaler has a turnover of four million euros in 2026. From January 1, 2027, every invoice to its business customers has to be an e-invoice – including those its online shop writes itself.

Example 2: A trade business has a turnover of around €600,000 in 2026. It may still send paper invoices in 2027 and has to send e-invoices from 2028. It already has to be able to receive them today.

Example 3: A manufacturer writes its invoices in Business Central but sends them as PDFs via an add-on program. Here it is not enough to switch the ERP. The add-on has to come along.

At the latest when you can answer “yes” to one of the following questions:

1. Was your total turnover in 2026 above €800,000?
2. Are your invoices created in more than one place – in the ERP, in the shop, in billing software?
3. Do you work with Business Central before version 26.3 or still with Dynamics NAV?
4. Do you send invoices as PDFs by email today?
5. Do you not know in which format your largest customers accept e-invoices?

1. Check your total turnover for 2026. It decides whether you have to send e-invoices from January 2027 or from January 2028.
2. Write down where invoices are created in your business.
3. Generate a test invoice as XRechnung and check it with the validator of KoSIT (Koordinierungsstelle für IT-Standards), the German coordination office for IT standards. The errors usually show up in the master data.
4. Ask your largest customers in which format and through which channel they accept e-invoices.
5. Plan the switch so that the first invoice run in January already uses the new format.

If you also pass accounting data to DATEV, check as well whether you use the DATEV invoice data service (Rechnungsdatenservice): DATEV is discontinuing it at the end of 2026.

At XCLRTD, we see more in e-invoicing than an obligation. Structuring your invoices properly once lays the foundation for everything that follows – less retyping, fewer queries, incoming invoices that assign themselves. Together we look at what your system can already do and close the gaps where they really are. Not with yet another add-on, but with the standard you already have.

E-invoicing is not a project for December – it is a project for now. If you check today, you will send in January without detours.