E-invoicing obligation 2027: changes above EUR 800,000

E-invoicing obligation 2027: what changes for companies above EUR 800,000 turnover

2025 was about receiving. From 1 January 2027 sending becomes serious — first for the larger companies. Anyone with more than EUR 800,000 total turnover in 2026 then loses the transition rule for paper and PDF invoices. What this concretely means and why receiving remains the more urgent task. As of October 2026.

Author: OzyCore GmbH · Editorial teamCreated: May 15, 2026Updated: Oct 11, 2026

Brief recap: what already applies

Since 1 January 2025 every company in domestic B2B must be able to receive e-invoices. That is not the future, that is the present. For sending a staged transition applies.

It is precisely this staging that causes confusion. Many hear “2027” or “2028” and conclude they still have time. For receiving that is wrong — it has long been mandatory.

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Timeline 2025 to 2028: receiving obligation 2025, transition 2026, sending obligation from EUR 800,000 in 2027, sending obligation for all in 2028. — The deadline schedule: receiving from 2025, sending staged through 2028.

The EUR 800,000 threshold

Until the end of 2026 every company may still issue an other invoice instead of an e-invoice: paper always, PDF only with the recipient's consent. This transition rule only covers invoices transmitted by 31 December 2026 (§ 27 (38) no. 1 UStG). From 2027 it falls away for companies with more than EUR 800,000 total turnover in the prior year. They must then issue structured e-invoices in domestic B2B.

Companies with no more than EUR 800,000 get one more year of transition. Decisive is the prior year's total turnover under § 19 (2) UStG — so whoever exceeds the threshold in 2026 is up in 2027. Regardless of size, EDI procedures remain allowed in 2027 with the recipient's consent. As of October 2026, § 27 (38) UStG applies unchanged; no postponement has been enacted.

What “sending obligation” means in practice

It means more than “rename PDF to XML”. Your outgoing invoices must have a norm-compliant format under EN 16931 — XRechnung or ZUGFeRD from version 2.0.1, not in the MINIMUM or BASIC-WL profiles — with all mandatory fields in the structured part, correct tax logic and a machine-readable structure. Small-amount invoices up to EUR 250 may still be issued as other invoices.

This concerns your invoicing or ERP system, your master data, possibly your number ranges. Such conversions need lead time — and only a few weeks remain until 1 January 2027.

Why receiving is the more urgent task

Here is the honest prioritization: sending has a deadline with lead time. Receiving has none — it applies now.

And from January 2027 it grows: every supplier above the threshold must then send e-invoices. If your intake does not work today, you have a problem today, not only in January. Sensible order: first set receiving up cleanly, then prepare sending.

A sensible order through 2027

Whoever proceeds in a structured way avoids the rush:

Now: ensure receiving — fixed address, validation, original archive.
By the end of 2026: check your 2026 total turnover — it decides whether you must issue e-invoices from 1 January 2027.
By the end of 2026: switch the invoicing/ERP system to e-invoice sending, tidy up master data, generate test invoices.
December 2026: inform customers; plan services from 2026 that are only invoiced in 2027 as e-invoices.
From 1 January 2027: issue invoices to domestic businesses as e-invoices, observing exceptions such as small amounts up to EUR 250.

Frequently asked questions

Who is affected by the sending obligation from 2027?

Companies with more than EUR 800,000 total turnover in the prior year. From 1 January 2027 they may no longer issue paper or PDF invoices in domestic B2B but must use e-invoices — except, for example, small-amount invoices up to EUR 250.

What applies to companies with up to EUR 800,000 turnover?

They have one more year: for supplies made in 2027, paper and — with consent — PDF remain allowed until the end of 2027; the e-invoice sending obligation applies to them from 2028. But they too must receive since 2025.

Does the turnover of 2026 or 2027 count?

Decisive is the prior year's total turnover under § 19 (2) UStG. Whoever is above EUR 800,000 in 2026 falls under the sending obligation in 2027.

Is it enough to rename my PDF to an XML?

No. The outgoing invoice must be a norm-compliant format under EN 16931 with all mandatory fields and correct tax logic — that concerns your invoicing or ERP system.

What is more pressing in 2027 — receiving or sending?

Receiving, because it has been mandatory without a deadline since 2025. Sending has lead time; it makes sense to set receiving up cleanly first.