The reform in one sentence
With the Growth Opportunities Act, § 14 UStG was reworded: in domestic B2B the structured e-invoice is the standard, plain PDF and paper are phased out. The Federal Ministry of Finance specified the details in its letter of 15 October 2024.
So much for the theory. The confusion only starts at “from when, for whom”.
The one misconception that throws everything off
The most common mistake: lumping receiving and sending together. They are regulated separately.
Everyone must receive — since 1 January 2025, with no transition period. Companies must send in stages, with several years of lead time. Anyone who hears “2027” or “2028” and thinks it does not concern them is wrong about receiving.
Receiving: since 2025, without exception
Every domestic company — from the small-business owner to the corporation — has had to accept and process e-invoices since the start of 2025. No consent is required; the sender decides the format.
This is the acute, often underestimated part of the obligation. There is no grace period to invoke here.
Sending: the staged schedule
For sending there is tolerance: until the end of 2026 paper and PDF may still be sent with the recipient's consent. From 2027 this ends for companies with more than EUR 800,000 prior-year turnover, from 2028 for everyone else in domestic B2B.
Small-business owners are exempt from issuing under current rules — but they too must receive.
What you really must do in 2025/2026
Sorted by urgency:
- Now: be able to receive e-invoices safely (fixed address, validation, original archive).
- Now: keep the XML original audit-proof, not just a PDF.
- 2026: check whether and from when you must send (turnover threshold).
- 2026/2027: prepare your invoicing system for norm-compliant sending.
- Throughout: keep receiving and sending mentally separate.