E-Rechnung: the timetable to 2028

Published 21 September 2026

Since 1 January 2025 every company based in Germany has had to be able to receive electronic invoices. That has been the case for a year and a half now, and it applies without exception. The obligation to send them, by contrast, arrives in stages, and the first of those is 1 January 2027. Because receiving and sending take effect at quite different moments, it is worth keeping the two apart.

What an E-Rechnung is, and what it is not

An E-Rechnung is an invoice in a structured format, in practice an XML file, that a program can read. The point of it is that the recipient’s bookkeeping can take the figures across directly, without anyone retyping them. Two formats are common in Germany: XRechnung and ZUGFeRD from version 2.0.1, bearing in mind that the MINIMUM and BASIC-WL profiles are not sufficient.

The point that causes the most confusion is this one: a PDF attached to an email is not an electronic invoice. It looks like a digital document, but no program can read the figures out of it, which is why since 2025 it sits in the same category as a printout. The technical term for it is „sonstige Rechnung“, an invoice of another kind.

The timetable

Four dates are enough to get your bearings:

What this means for you

Which stage applies to you depends on one figure alone: your total turnover for 2026. Three cases cover almost every situation:

You are a Kleinunternehmer under § 19 UStG. Then you will never have to issue an electronic invoice, and that is a permanent exemption rather than a postponement. You do still have to be able to receive them, like everyone else, and that has applied since 2025.

Your 2026 turnover is below €800,000. For you the obligation to send starts only on 1 January 2028, so you have a good year longer than larger businesses. There is one thing to watch, though: from January 2027 your larger suppliers will start sending you XML instead of PDFs. Your inbox therefore changes a full year before the way you invoice does.

Your 2026 turnover is above €800,000. Then you must issue electronic invoices from 1 January 2027, which makes 2026 the year to prepare the changeover without rushing.

What may still go on paper

A whole set of exceptions remains in place after 2028 as well, and it covers more than people tend to assume: invoices up to €250 gross, travel tickets, services provided by Kleinunternehmer, and invoices to private individuals and to associations that do not trade. For many small businesses, a good part of the everyday work therefore falls outside the obligation altogether.

Three things you can do now

1. Settle on an inbox you actually read. Legally, a single address for incoming invoices is entirely sufficient. It simply has to work reliably and be emptied regularly, otherwise invoices will eventually sit there that nobody knows about.

2. Keep the XML file, not the printout. For eight years, unaltered, in the original. A PDF printout is convenient to look at, but it does not replace the structured file.

3. Check what your invoicing software can already do. Most of the common programs now produce XRechnung or ZUGFeRD at the press of a button. Often the function is already there and simply switched off, which makes the changeover far less work than feared.

General information as at September 2026 – not advice on an individual case.
Sources: § 14 and § 27 (38) UStG, § 34a UStDV, Federal Ministry of Finance FAQ on the E-Rechnung (March 2026).

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