E-invoicing obligation 2027 and 2028: What the self-employed and small businesses need to do now

From 1 January 2025, all companies in Germany must be able to receive e-invoices. The full sending obligation will come in stages: from 2027 for companies with a turnover of over €800,000 in the previous year, and from 2028 for all others - with the exception of small businesses. For the self-employed and small businesses, this means that there is still time to prepare, but not for long.

This article shows clearly and without marketing-speak what exactly you can expect, what already applies today, which invoices are not affected (many forget this), how you can technically receive and send invoices - and what stumbling blocks there are when it comes to archiving.

Note in advance: The content of this article has been carefully researched to the best of our knowledge and is based on publicly accessible sources - in particular the FAQs of the Federal Ministry of Finance (BMF) on e-invoicing, the BMF letters of 15 October 2024 and 15 October 2025, the publications of the Chambers of Industry and Commerce and the relevant legal bases. Tax law is constantly evolving and each individual case has its own set of rules. Please speak to your tax advisor for reliable information on your situation - this article is not tax advice and does not replace it.

What is it all about - what is an e-invoice?

An e-invoice in the sense of the definition in force since 2025 is not simply a PDF by e-mail. An e-invoice is an invoice that

• is issued, transmitted and received in a structured electronic format,
• enables electronic processing, and
• fulfils the requirements of the European standard EN 16931.

Specifically authorised in Germany are in particular

• XRechnung - pure XML, maintained by KoSIT (Coordination Centre for IT Standards). Current productive standard: XRechnung 3.0.2. In March 2026, KoSIT announced XRechnung 4.0 (based on the updated EN 16931-1:2026 standard), which is particularly relevant for production in connection with the EU initiative "VAT in the Digital Age" (ViDA).
• ZUGFeRD from version 2.0.1 - Hybrid format: PDF/A-3 with embedded XML. Current version: ZUGFeRD 2.3. The MINIMUM and BASIC-WL profiles do not** fulfil the requirements of the e-invoicing obligation - they are pure data exchange profiles without complete invoice data and will not be sufficient from the end of the transition periods.
• EDI procedure (e.g. EDIFACT) under certain conditions

Which is not an e-invoice and will no longer be sufficient from the end of the transition periods:

• A PDF file sent by email (not even "PDF with a bit of XML embedded")
• A scanned paper receipt
• A Word/Excel document
• A pretty online form without structured machine readability

These formats are considered "other invoices ". They are still permitted during the transitional periods - after that they are no longer permitted (except in the special cases below).

The timetable at a glance

Important: The obligation to receive invoices already applies today, since 1 January 2025 - even if you do not yet send e-invoices yourself. If a B2B customer sends you an e-invoice in XRechnung or ZUGFeRD format, you must be able to process and archive it.

What does this mean in concrete terms - depending on your size

Large companies with previous year's turnover > €800,000

From 1 January 2027 you must issue e-invoices for all domestic B2B sales. Latest sensible date for the changeover: second half of 2026.

SMEs with previous year's turnover up to €800,000

You have one year longer - mandatory dispatch begins on 1.1.2028. But: From 2027, many of your major customers will already be sending e-invoices exclusively - so you need to be able to receive and process them before then.

Self-employed persons, freelancers, sole traders

Practical like SMEs: mandatory dispatch from 1.1.2028. If you only have very low turnover or are already a small business owner (see below), you have even more leeway.

Small business owner according to § 19 UStG

You are permanently exempt from shipping (§ 34a UStDV). You may continue to issue PDF and paper documents. But you must be able to receive - just like all other entrepreneurs.

Obligation to receive - which is already mandatory today

The obligation to receive is a point that is underestimated by many. Sure, if you don't have to send e-invoices yet, you can sit back and relax. But if your next B2B customer - e.g. a larger client, a limited company, a group - switches to e-invoicing, you are obliged to receive, not the sender.

What you must be able to do:

• Receive the format (XRechnung / ZUGFeRD) - typically by e-mail
• Processing** - display of the human-readable content (e.g. visualisation of the XML data)
• Archiving of the structured data (see archiving section)

Good news: The BMF clarifies that an email inbox is technically sufficient for receiving**. This means that you do not necessarily need expensive specialised software just for receiving. However, you do need processing and archiving software.

XRechnung vs. ZUGFeRD - which format is the right one?

Both formats are permitted. Which one you use depends on who you are working with:

Rule of thumb for practice:

• Mainly B2B with mixed recipient structure (small and large customers, manual and automated processing) → ZUGFeRD is usually the more pragmatic choice
• You deliver to public clients (authorities) → XRechnung is mandatory here
• You know that your customer wants a specific form → ask them what they prefer - both are legally equivalent

Important exceptions that many overlook

Not every invoice has to be an e-invoice - not even after 2028. The following cases are permanently excluded:

Small value invoices up to €250 gross

Invoices whose total gross amount does not exceed €250 may continue to be issued as "other invoices" (paper, PDF). This covers typical receipts, small purchases of materials, petrol receipts, etc.

Tickets

Tickets (train tickets, bus/flight tickets, etc.) that are considered invoices do not also have to be sent as e-invoices.

Invoices to end consumers (B2C)

If you sell to private individuals, these sales are not subject to the e-invoice obligation - even after 2028. Electronic transmission to private customers still requires their consent.

Invoices to the public sector (B2G)

A specific regulation applies here - the federal E-RechVO and corresponding state regulations. Anyone supplying public authorities has had to invoice in XRechnung format for some time now.

Tax-free sales according to § 4 No. 8 - 29 UStG

Certain tax-free services (financial services, rentals, medical professions in part, etc.) are also exempt from the e-invoicing obligation. The individual case should be checked with the tax consultant.

Supplies to legal entities that are not entrepreneurs

E.g. many associations, some foundations - do not fall under the e-invoicing obligation, depending on the constellation.

Archiving: What many will do wrong

There's a real trap lurking here, which is neglected in many guides.

**You must store the e-invoice in its original, structured form:

• For XRechnung: Archive the XML file itself - not just a printed or visualised PDF printout
• For ZUGFeRD:** The hybrid PDF/A-3 file with the embedded XML - not just the visible PDF extracted from it
• Retention period: 8 years for invoices as accounting documents (§ 147 para. 3 AO, shortened from 10 to 8 years by the Fourth Bureaucracy Relief Act - application to all documents whose deadline had not yet expired at the beginning of 2025). Attention: For trade books, inventories, opening balance sheets, annual financial statements and management reports, the 10 years deadline remains - anyone who prepares balance sheets or their own accounting must also observe this longer deadline.
• Format: Unchanged in the original electronic form

What is not enough:

• Printing a visualisation as a PDF and saving the PDF → the structured data is lost
• Store the invoice in a pure image format (e.g. JPG, scanned PDF) → no longer machine-readable

What most people are already doing wrong today: Incoming ZUGFeRD invoices are "printed" and only the visually readable PDF is stored. This would violate the retention obligation for the structured data.

The BMF has clarified in a simplification that archiving does not necessarily have to take place in a GoBD-compliant DMS - but you must at least ensure that the structured part remains intact in its original form.

Attachments are permitted - not everything has to be included in the XML

A common concern: "How do my extensive construction service breakdowns or detailed tables fit into a structured XRechnung?" Answer: Not at all - and they don't have to.

Supplementary content may continue to be part of the e-invoice as an unstructured attachment (e.g. PDF). The BMF explicitly mentions construction services as an example: The structured part contains the trades with totals, the PDF attachment contains the detailed breakdown. In the case of final invoices, the offsetting of discounts can also be shown in the unstructured appendix.

This provides scope for typical constellations from the trades, construction and consultancy practice.

Transmission method - no specification

The BMF does not specify how the e-invoice is received by the recipient:

• Email (with attachment) - the easiest way
• Electronic interface** (API, EDI)
• Shared storage location** within the group of companies
• Internet portal** for download
• Theoretically also USB stick - if both sides agree

The transmission channel must be clarified "under civil law between the contracting parties". In practice: e-mail attachment is sufficient for most constellations.

If suppliers still send other invoices - what to do?

A question that comes up all the time in practice:

• During the transition periods (i.e. until the end of 2026 or the end of 2027, depending on the size of the supplier): Other invoices (paper/PDF) are still permitted. They also count as a proper invoice for the pre-tax deduction.
• After the end of the respective transition period:** Other invoices no longer fulfil the formal requirements. Input tax deduction can become critical here - the supplier is obliged to submit a correct e-invoice at a later date.
• Practical recommendation:** Inform suppliers of the upcoming requirements at an early stage - small tradespeople or sole traders in particular often still need time to prepare themselves.

Practical checklist 2026/2027

• [ ] Set up a mailbox for receiving e-invoices - either a separate address (e.g. rechnungen@ihrefirma.de) or an integrated e-invoice mailbox in the accounting software
• [ ] Clarify processing software: Visualisation of XRechnung-XML, readout of ZUGFeRD-XML
• [ ] Review archiving strategy - back up structured original files, not just PDF printouts
• [ ] Consider retention period of 8 years in the backup/archiving strategy
• [ ] Check invoicing software for e-invoice dispatch (XRechnung and ZUGFeRD ≥ 2.0.1)
• [ ] Format decision for own dispatch: ZUGFeRD for mixed B2B recipients, XRechnung for public authority customers
• [ ] Inform suppliers in good time in which format you can receive e-invoices
• [ ] For previous year's turnover 2026 > € 800,000: Ensure readiness for dispatch by 1 January 2027
• [ ] For previous year's turnover 2026 ≤ € 800,000: Ensure readiness for dispatch by 1 January 2028
• [ ] Small businesses: Ensure readiness for receipt and archiving - you remain exempt for shipping
• [ ] Master data: VAT ID no. of your own company correctly entered? Have you maintained your customers' e-mail addresses?
• [ ] Clarify attachment strategy: How should extensive detailed lists, timesheets, construction breakdowns be supplied? As an unstructured PDF attachment in the ZUGFeRD or XRechnung consignment?

How modern invoicing software supports

Cloud invoicing software such as Easy Invoice in the PepperTools Office Cloud takes care of some of the above steps:

• Sending as XRechnung and ZUGFeRD with the latest profile versions that fulfil EN 16931
• Receiving e-invoices and displaying the human-readable content - without the need for a separate visualisation tool
• Archiving of structured original files** in the integrated document management system (DMS), protected against subsequent changes - complies with the 8-year retention obligation
• Attachments** (e.g. detailed statements, timesheets) can be sent as an unstructured PDF in the e-invoice
• Small business mode with correct reference to §19 UStG - and at the same time e-invoice receipt readiness in the same system
• Multilingual documents** for international B2B customers - the ZUGFeRD invoice can be rendered in the customer's document language

➔ Test Easy Invoice | ➔ Compare packages

Conclusion

The e-invoice obligation is coming gradually - receiving since 2025, sending for large companies from 2027, for all others from 2028. Small businesses are permanently exempt for sending, but not for receiving.

Three key points that many underestimate:

1. Duty to receive already applies today - even for small businesses

2 The archiving must concern the structured part, not just a PDF printout of the invoice 3 Important exceptions remain - low-value invoices up to €250, tickets, B2C, certain tax-free transactions

If you set up receipt, processing and archiving properly now, you will not have any short-term stress migrations in 2027/2028 and can relax and switch on dispatch on your own deadline.

Sources and further information

The statements in this article are based in particular on the following publicly accessible sources:

• Federal Ministry of Finance - FAQ on e-invoicing: bundesfinanzministerium.de/Content/DE/FAQ/e-rechnung.html
• BMF letter on e-invoicing dated 15 October 2024 (first BMF letter) and 15 October 2025 (second BMF letter - clarifications and additions)
• Growth Opportunities Act** (introduction of the e-invoicing obligation in Section 14 UStG)
• § 14 UStG (issuing invoices) - gesetze-im-internet.de/ustg_1980/__14.html
• § 34a UStDV (exemption of small businesses from the obligation to send e-invoices)
• European standard EN 16931** (technical basis for structured formats)
• KoSIT - Standard XRechnung - currently productive Version 3.0.2; Version 4.0** announced in March 2026 (based on EN 16931-1:2026, relevant for ViDA): xeinkauf.de/xrechnung/versionen-und-bundles
• FeRD - Forum elektronische Rechnung Deutschland - Specification ZUGFeRD 2.3** (EN 16931 / EXTENDED profiles fulfil the e-invoice obligation; MINIMUM and BASIC-WL do not)
• § 147 para. 3 AO and Viertes Bürokratieentlastungsgesetz (BEG IV) - shortening of the retention period for accounting documents from 10 to 8 years from 2025
• IHK publications** on the e-invoicing obligation (e.g. IHK Frankfurt, IHK Darmstadt, IHK Dresden)
• E-Invoicing Ordinance of the Federal Government (E-RechVO)** for the B2G sector

Status of research: May 2026. Later BMF letters or legislation may modify the statements presented here - if in doubt, please check the current version of the sources mentioned or consult your tax advisor.