In Germany, the next stage of the e-invoicing mandate starts in seven weeks. From 1 January 2027, businesses whose total turnover in 2026 was above 800,000 euros must send invoices to other German businesses as a structured e-invoice (E-Rechnung). On 15 October 2026 the Federal Ministry of Finance (Bundesfinanzministerium, BMF) published a third guidance letter on the subject that settles several practical questions. Most freelancers are below the threshold and get one more year before they have to issue e-invoices. The receipts you collect yourself will still start to change in January.
The timeline to 2028
The deadlines are set out in the transitional rules of § 27(38) UStG, the German VAT Act (as of November 2026). For invoices between businesses established in Germany:
| Supplies made in | Receiving | Issuing |
|---|---|---|
| 2025 and 2026 | required for all | paper, or PDF with consent, still allowed |
| 2027 | required for all | e-invoice if prior-year turnover above 800,000 euros, otherwise paper or PDF |
| 2028 onwards | required for all | e-invoice for everyone, exemptions remain |
The threshold refers to the previous year's total turnover (Gesamtumsatz) as defined in § 19(2) UStG: in essence, the sum of your taxable supplies, calculated on the payments you actually received (as of November 2026). For 2027, your 2026 turnover counts. Existing EDI exchanges that do not use an e-invoice format may be used by every business until the end of 2027.
Watch out: Read literally, the general transitional rule in § 27(38) no. 1 only covers invoices for 2025 and 2026 supplies that are sent by 31 December 2026. The extension for smaller businesses in no. 2 covers supplies made in 2027. Work you do in December but invoice in January therefore falls under neither rule, going by the wording. It is safer to invoice December work in December, or to send it as an e-invoice straight away.
What counts as an e-invoice, and who is exempt
Under § 14(1) UStG, an e-invoice is an invoice in a structured electronic format that allows electronic processing. The format has to follow the European standard EN 16931, or be agreed between you and your client, provided all mandatory details can be extracted from it completely. According to the BMF, XRechnung and ZUGFeRD from version 2.0.1 meet these requirements, except for the MINIMUM and BASIC-WL profiles (as of November 2026). A PDF sent by email is not an e-invoice; it counts as an "other invoice" (sonstige Rechnung). Our guide to ZUGFeRD and XRechnung explains how the two formats differ.
Even after 2027, you do not need an e-invoice in these cases:
- Invoices to private customers and many VAT-exempt supplies, because German VAT law does not require an invoice there in the first place.
- Small-amount invoices of up to 250 euros gross, which § 33 UStDV allows to be sent as an other invoice at any time (as of November 2026).
- Travel tickets that count as invoices under § 34 UStDV.
- Invoices from small businesses using the VAT exemption (Kleinunternehmer), for which § 34a UStDV says the same.
You still have to be able to receive e-invoices, small businesses included. According to the BMF, an email inbox is enough. If you leave the small business scheme and start charging VAT, the issuing obligation applies to you from that point.
What the BMF letter of 15 October 2026 clarifies
The new BMF letter adds to the letters of 2024 and 2025 and amends the administration's VAT guidelines (Umsatzsteuer-Anwendungserlass). Four points matter most for freelancers (as of November 2026):
- The description of the service belongs in the XML. All mandatory details have to be in the structured part. The description must identify the service clearly enough to check the VAT rate, the place of supply and the client's right to deduct input VAT (Vorsteuer). Extra detail such as timesheets can travel as an embedded attachment.
- Advance invoices stay simple. Advance or instalment invoices you issue before your e-invoicing obligation starts do not have to be e-invoices, even if the work and the payment come later. Final invoices get a simplification until 30 June 2030.
- No administrative offence. Issuing an other invoice where an e-invoice is required is not an administrative offence under § 26a UStG, the BMF says. Its FAQ adds that your client has a civil-law claim to an e-invoice, and their input VAT deduction depends on it.
- Grace period for the new details. E-invoices issued by 31 December 2026 that follow the 2024 and 2025 letters are accepted, including for input VAT, even if they miss the new requirements.
New from January: the till receipt above 250 euros
For your own purchases, one answer in the BMF FAQ matters: there are no special rules for cash payments. If you buy supplies for your business at a DIY store or take clients out to a restaurant and the bill is above 250 euros, the seller has to issue an e-invoice unless they can and want to use the transitional rules (as of November 2026). From 2027, that applies to shops and restaurants whose turnover in the previous year was above 800,000 euros.
The BMF describes a practical route: you get the normal till receipt on the spot, and the seller emails the e-invoice later as a correction of that receipt. To do that, the seller can ask for your email address at the till.
If no e-invoice arrives although one was required, the till receipt is in principle not a valid invoice for reclaiming input VAT. According to the BMF, the deduction can currently still be possible, for example when the receipt contains all the required details correctly. It is also not challenged if you could assume the seller was still allowed to use the transitional rules. What you know about the seller counts, though, such as their known size.
With hybrid ZUGFeRD invoices, the XML data is what counts, not the PDF image. An XRechnung has no image at all. The German tax administration offers a free viewer for both in its ELSTER portal.
Tip: Set up a separate email address just for incoming invoices and give it at the till for larger purchases. Keep the original file: under § 14b UStG, invoices must be kept for eight years, and for an e-invoice at least the structured part has to be stored intact in its original form, according to the BMF (as of November 2026). A printout does not do that.
What this means for you
- Check your 2026 total turnover. If it was above 800,000 euros, invoices to German businesses have to be e-invoices from 1 January 2027. If you are close to the line, clear it up with your tax advisor (Steuerberater) now.
- If you are below it, use 2027 to move your invoicing tool to XRechnung or ZUGFeRD. From 2028, e-invoices are required for everyone.
- Invoice December work in December, or send that invoice as an e-invoice.
- As a small business under the VAT exemption, you can keep sending paper or PDF invoices, but you must be able to receive e-invoices.
- For purchases above 250 euros, give your invoice address at the till and archive the original XML file.
Bonro reads ZUGFeRD and XRechnung e-invoices straight from the XML data, the part that counts for tax purposes, rather than through text recognition. You forward the invoice to your private @in.bonro.app address or upload it on the web dashboard, check the fields, and pass it on to your tax advisor in the DATEV export. Try Bonro
Sources
- BMF-Schreiben vom 15. Oktober 2026 – Einführung der obligatorischen elektronischen Rechnung, ergänzende Regelungenbundesfinanzministerium.de
- Bundesfinanzministerium – Fragen und Antworten zur E-Rechnungbundesfinanzministerium.de
- § 14 UStG – Ausstellung von Rechnungengesetze-im-internet.de
- § 27 UStG – Allgemeine Übergangsvorschriftengesetze-im-internet.de
- § 19 UStG – Besteuerung der Kleinunternehmergesetze-im-internet.de
- § 33 UStDV – Rechnungen über Kleinbeträgegesetze-im-internet.de
- § 34a UStDV – Rechnungen von Kleinunternehmerngesetze-im-internet.de
- § 14b UStG – Aufbewahrung von Rechnungengesetze-im-internet.de
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