The news
Germany's Federal Ministry of Finance (BMF) issued a third letter on mandatory e-invoicing on 15 October 2026. From 1 January 2027, a business in Germany that sells to another business in Germany must, as a rule, send a structured e-invoice that follows the European standard EN 16931, such as XRechnung or ZUGFeRD. A plain PDF attached to an email does not meet the rule.
The VAT law allows two exceptions in 2027. A business whose total turnover in 2026 was no more than €800,000 may keep sending paper invoices, or PDF invoices if the customer agrees, until 31 December 2027. Invoices exchanged through EDI may also continue until the end of 2027 if the customer agrees. Every business has had to be able to receive e-invoices since 1 January 2025.
According to summaries by the tax publisher Haufe and the advisory firm Ebner Stolz, the new letter says that tax-relevant details and the description of the service belong in the structured part of the file, not only in an attachment. A file that breaks one of the standard's business rules generally still counts as an e-invoice for VAT, as long as the required invoice details are complete and correct. Businesses with many customers only need to check whether a customer is a business when a contract starts or changes.
E-invoices issued until 31 December 2026 that follow the ministry's earlier letters are still accepted. For final invoices after advance payments, a simpler way to show the amounts already paid is allowed until 30 June 2030.
What it means for you
- If your total turnover in 2026 is above €800,000, your invoices to German business customers must, as a rule, be e-invoices from 1 January 2027.
- Smaller businesses get one more year, and the same rule applies to them from 1 January 2028.
- Your accounting or ERP system has to put all VAT details into the XRechnung or ZUGFeRD data itself, not only into a readable PDF view.
- Invoices to private consumers are not covered by this obligation.
What to do now
- Estimate your total turnover for 2026 and compare it with the €800,000 line.
- Ask your software provider for a test XRechnung or ZUGFeRD invoice from your own system and have your tax adviser check it.
- Agree with your largest customers which format and channel they will accept from January.
- Make sure the e-invoices you receive go straight into your accounts instead of being printed and typed in again.
How Didset can help
We can connect your ERP or invoicing system to XRechnung and ZUGFeRD, so e-invoices go out and come in without manual work.
Talk to us about it
