Germany e-invoicing 2027-2028 Timeline

Plan for Germany's phased B2B e-invoicing rollout in 2027-2028. Generate EN 16931 Factur-X and XRechnung-ready invoices before your ERP cutover.

What this covers

• Issuer and recipient obligations across the phased 2027-2028 rollout windows.
• Factur-X PDF with embedded CII XML for trading partners during the transition.
• XRechnung XML with buyer-reference enforcement for CII-only delivery.

Receive

Mandatory since Jan 2025

Issue

Jan 2027 if turnover >€800k

Format

Any EN 16931-compliant

The 2027–2028 issuance thresholds

German receiving capability has been mandatory since January 2025. Issuance then phases in by size: from 1 January 2027, businesses with prior-year turnover above EUR 800,000 must issue structured e-invoices for domestic B2B; from 1 January 2028, the obligation covers all remaining businesses. During the transition window, an issuer may still send paper or unstructured PDF — but only until their tier's deadline, and only where the buyer consents to a non-structured format.

The asymmetry matters for planning: your larger customers may be obliged to issue structured invoices before you are, and they are already obliged to receive yours. A supplier who can emit compliant XRechnung or Factur-X early is easier to keep — finance teams do not enjoy manually keying PDF invoices into systems built for structured data.

Choosing a format and channel

Any EN 16931-compliant format satisfies the law: XRechnung (pure UBL or CII XML), ZUGFeRD/Factur-X hybrids, or Peppol BIS. For public-sector buyers the federal standard is XRechnung with a Leitweg-ID routing address; some states add their own rules, so check the buyer's invoice portal guidance. For B2B, hybrid Factur-X is the lowest-friction option — it looks like a normal invoice to humans while carrying the XML machines need.

On the channel side there is no central platform: delivery is whatever the parties agree — email, portal upload, EDI, or increasingly Peppol. Peppol is worth adopting early rather than late: it solves addressing, format negotiation, and audit trail in one network, and it is the rail Belgium and other neighbors already mandate.

Validation pitfalls to fix before your deadline

The three most common rejection causes across EN 16931 invoices are mismatched totals (line sums not reconciling to document totals per BR-CO rules), missing or malformed buyer references, and VAT category codes that do not match the rate applied. None of these are format problems — they are data problems that any downstream validator will catch.

A workable readiness plan is unglamorous: generate a representative sample invoice from real data, validate it against the EN 16931 rule set and, for public-sector flows, the XRechnung Schematron, then fix the upstream fields that fail. Doing this in 2026 while PDFs are still legal costs hours; doing it after your obligation date costs rejected invoices and delayed payment.

Last reviewed September 2026 by the Eurorix team.