Issuing e-invoices from 2027: what the 800,000-euro threshold means

The transitional rules for e-invoicing end in two stages. For supplies up to 31 December 2026, all businesses may still send paper invoices or, with the recipient's consent, PDF invoices to other domestic businesses. From 1 January 2027, this relief will only apply to some businesses (§ 27 Abs. 38 UStG).

The 800,000-euro threshold

Anyone who generates a total turnover of more than 800,000 euros in the 2026 calendar year must issue e-invoices to other domestic businesses for supplies from 2027 onwards. The relevant figure is total turnover under § 19 Abs. 2 UStG, which therefore includes turnover with private customers. A trade business that works mainly for private households can thus exceed the threshold even though it has only a few commercial clients.

Businesses with turnover of up to 800,000 euros may continue to use paper or, with consent, PDF for supplies in 2027, provided the invoice is sent by 31 December 2027. There is also a separate transitional rule until the end of 2027 for invoices sent via EDI, regardless of turnover. From 2028, the obligation applies to everyone.

Low-value invoices up to 250 euros, travel tickets and invoices from small businesses remain permanently exempt. The obligation does not apply to invoices to private customers in any case. However, all businesses must be able to receive e-invoices, even if they are not yet required to issue them themselves.

The third BMF circular of 15 October 2026

The Federal Ministry of Finance (Bundesfinanzministerium) published a third circular on e-invoicing on 15 October 2026. It supplements the circulars of 15 October 2024 and 15 October 2025. Among other things, it clarifies the description of the supply in the structured part and contains relief for construction services and for advance and final invoices. E-invoices issued by 31 December 2026 that comply with the two earlier circulars will not be objected to. The circular does not postpone the statutory changeover dates.

What needs to be clarified before the end of the year

• Project your total turnover for 2026 and check whether the threshold will be exceeded.
• Check with your invoicing software provider whether it generates XRechnung or ZUGFeRD in a permitted profile (not MINIMUM or BASIC-WL).
• Ask your business customers for their address for receiving e-invoices and store it in your master data.
• Define the process for interim and final invoices, for which the new BMF circular contains specific rules.

DELA is preparing a training course on e-invoicing on this topic.