Do you have to issue e-invoices starting January 1, 2027?

The obligation to issue e-invoices begins on January 1, 2027 for companies whose total turnover in 2026 exceeds 800,000. All other domestic companies must follow from January 1, 2028, as soon as they invoice other domestic companies. This is how the IHK Region Stuttgart summarizes the stages.

Whether the obligation applies to you in 2027 or only in 2028 depends on your prior-year turnover. For both cases, the Federal Ministry of Finance (BMF) issued a supplementary letter on October 15, 2026. The text governs the handling of advance payments, final invoices, corrections and service descriptions.

Who has to issue them, and when?

Since January 1, 2025, all domestic businesses must be able to receive and store e-invoices, including small businesses and associations. A phased plan applies to issuing them.

Invoices to end consumers, tax-exempt transactions under § 4 numbers 8 to 29 UStG, small-amount invoices and tickets do not require an e-invoice. According to § 34a of the VAT Implementation Regulation, small businesses do not have to issue them. Only a structured format conforming to the EN 16931 standard, such as XRechnung or ZUGFeRD from version 2.0.1, counts as an e-invoice. A PDF file sent by email does not fulfill the obligation; since 2025 the IHK classifies it as an other invoice.

What else does the BMF letter regulate?

The letter supplements the papers from October 2024 and October 2025. The most important new points:

• Down payment, advance and installment invoices that you issue before your mandatory start date do not require an e-invoice, even if the service and payment follow later.
• For a final invoice, the tax administration will not object until June 30, 2030 if you deduct partial amounts already paid as a total in the field for the amount already paid (BT-113) and state the details in the free-text field for invoice notes (BT-22).
• The type, scope and, where applicable, place of the service must be stated in the structured part so clearly that the tax rate and place of supply can be verified. Time sheets may go into an embedded attachment, such as a PDF file.
• A correction must also be issued as an e-invoice, with the invoice type for corrections. Which type fits which case is still technically open. The BMF currently accepts any suitable solution.
• If a file violates a content validation rule of the standard but not the format, it remains an e-invoice for VAT purposes, provided the mandatory details are correct and complete.
• An other invoice instead of a required e-invoice is not an administrative offense under § 26a paragraph 2 number 1 UStG. This section says nothing about the recipient's input tax deduction.

What this means for you

It is best to first check which stage you fall into. According to the IHK, the decisive factor is the previous year's total turnover. If you are below the threshold, you may continue to issue paper invoices in 2027, and with the recipient's consent also other electronic invoices. The obligation to receive already applies to you now. As a transitional solution, an email inbox is sufficient according to the IHK, and a portal such as Elster can be used for reading.

It is best to ask your invoicing software provider whether it generates XRechnung or ZUGFeRD and can embed attachments. An invoice template from Word or Canva that you export as a PDF does not produce an e-invoice. Feel free to test the switch as early as December with a real invoice.

Our assessment: In future, describe services so precisely that type and scope are recognizable, for example "design of a logo with three drafts" instead of "design services". The BMF does not require an exhaustive list, but a clear identification. The details belong in the attachment. The rules concern transactions between businesses established in Germany; they do not apply to Austria and Switzerland.

The BMF dated its letter October 15, 2026, and the IHK Region Stuttgart published its overview as of the same day.

Sources

• Federal Ministry of Finance: Introduction of mandatory electronic invoicing for transactions between domestic businesses from January 1, 2025, supplementary regulations
• IHK Region Stuttgart: End of the transition period for high-turnover companies