E-invoicing in Germany: what changes on 1 January 2027

Germany is moving business-to-business invoices from paper and PDF to structured e-invoices in three steps. The first step is already behind us, the second starts on 1 January 2027, and the third a year later. This post lists what the law asks for at each step and how Scipio ERP covers it.

The rules apply to invoices between businesses in Germany. Invoices to consumers are not affected.

The three dates#

Through 2027, invoices in an EDI format that you have agreed with your customer also stay allowed.

The legal basis is § 14 and § 27 (38) of the German VAT Act (UStG), and the details are in the letter of the Federal Ministry of Finance of 15 October 2025, which replaced parts of its first letter of 15 October 2024.

The exceptions#

• Small invoices: an invoice with a total of up to EUR 250 (Kleinbetragsrechnung) may stay a paper or PDF invoice.
• Small businesses: a Kleinunternehmer under § 19 UStG need not issue e-invoices.

Both must still be able to receive an e-invoice. The duty to receive has no exception.

What counts as an e-invoice#

An e-invoice is a structured file that follows the European standard EN 16931, so a system can read it without a person typing it in. Two formats are named:

• XRechnung, an XML file in the UBL or the CII syntax.
• ZUGFeRD, a PDF with the XML inside, from version 2.0.1, but not in the profiles MINIMUM and BASIC-WL, which carry too little data.

A PDF without the data inside is not an e-invoice, however tidy it looks. The letter of October 2025 adds one point: a file with a format error is not an e-invoice either.

What you need before your first e-invoice#

An e-invoice carries more data than most printed invoices did, and a validator rejects the file when a field is missing. Collect these before the first one:

1. Your VAT ID, your tax number and your commercial register number.
2. The IBAN that goes on the invoice.
3. A contact person with a name, a phone number and an email address. XRechnung requires one.
4. For each business customer: the format they take, and the inbox for e-invoices if it is not their billing email. Public authorities also need their Leitweg-ID on every invoice.
5. A VAT category on each tax rate: standard, zero rated, exempt, reverse charge, intra-community supply, export, or not subject to VAT.

How Scipio ERP does it#

Scipio ERP 4.0 writes XRechnung (UBL and CII), ZUGFeRD / Factur-X and Peppol BIS Billing 3.0 out of the sales invoice you already have. You set the company data once, and each customer gets a format and a delivery channel: an email attachment, a download for the customer’s portal, or Peppol. The files pass the official KoSIT validator with the XRechnung 3.0.2 configuration, and the ZUGFeRD PDF passes the Mustang validator with veraPDF.

Receiving works the other way round. Under Accounting › Import/Export › Receive e-invoice you upload an XRechnung, any EN 16931 file or a ZUGFeRD PDF, and Scipio ERP makes a purchase invoice out of it. It finds the supplier by the VAT ID in the file, books the lines and the VAT per rate, refuses the same invoice a second time, and keeps the original file with the invoice, readable as a page.

A Kleinunternehmer sets one flag in the e-invoice settings, and the invoice then carries the exemption text and its code. The step-by-step guide, with every field, is in the documentation: E-Invoicing: XRechnung, ZUGFeRD and Peppol .

A checklist for the rest of 2026#

• Check your turnover for 2026. Above EUR 800,000, your invoices to German businesses must be e-invoices from the first invoice of 2027.
• Send one test e-invoice to each of your largest customers now, and ask them whether their system took it.
• Ask your suppliers to send you e-invoices. You must accept them already.
• Fill in the five points above for your company and your customers.
• Below EUR 800,000, plan the switch for 2027 anyway. From 2028 there is no threshold.

This post describes the law as of 10 November 2026. It is not tax advice; your tax adviser knows your case.

Sources#

• Federal Ministry of Finance, letter of 15 October 2025 on the mandatory e-invoice (PDF, German)
• § 27 UStG, transition rules (German)
• § 14 UStG, the invoice (German)
• XRechnung versions at KoSIT