E-invoicing obligation 2028: roadmap for SMEs

The staged plan, short and clear

Receiving: everyone since 2025. Sending, staged: until the end of 2026 transition (paper always, PDF with the recipient's consent), from 2027 a sending obligation for companies above EUR 800,000 prior-year turnover, from 1 January 2028 for everyone else in domestic B2B.

So 2028 is not a new starting point but the end of the last transition rules for sending. Only the exceptions for Kleinunternehmer, small-amount invoices up to EUR 250 and passenger tickets remain permanently.

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Timeline emphasizing 2028: receiving 2025, transition 2026, from EUR 800,000 in 2027, all B2B in 2028. — 2028 ends the last transition period — the sending obligation then applies to everyone in B2B.

Who exactly is affected in 2028

Affected are the companies that could still use the transition rule in 2027 because their 2026 total turnover was not above EUR 800,000. From 2028 this possibility falls away. The special rule for EDI procedures that do not meet the e-invoice requirements also ends at the end of 2027.

Not affected are small businesses under the Kleinunternehmer scheme (§ 19 UStG): under § 34a UStDV they may keep issuing other invoices after 2027. So a “small company” and a “Kleinunternehmer” are not the same thing. Whoever is small today but taxed under the standard rules should not dismiss 2028 as “far off”.

Sending in 2028 means a real format

From 2028 a PDF is no longer enough. Outgoing invoices must be 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 and correct tax logic.

This concerns your invoicing or ERP system and your master data. Such conversions are better planned calmly during 2027 than under time pressure in December.

Why receiving is the present

The recurring, important point: while sending has a deadline with lead time, receiving has none. It has applied since 2025.

Whoever has 2028 in mind but does not process incoming XRechnung cleanly today prioritizes wrongly. First secure receiving, then prepare sending for 2028 at leisure.

Roadmap for small companies

Without the rush:

Now: ensure receiving — fixed address, validation, original archive.
By the end of 2026: check your 2026 total turnover — above EUR 800,000 the sending obligation already starts on 1 January 2027.
2027: switch the invoicing/ERP system to norm-compliant sending.
2027: tidy up master data, generate test invoices, inform customers.
From 1 January 2028: invoices to domestic businesses only as e-invoices — except small amounts up to EUR 250.

Frequently asked questions

What applies from 2028 for the e-invoice?

From 1 January 2028 the smaller companies in domestic B2B must also issue e-invoices. The last transition rules for paper, PDF and EDI run out at the end of 2027. Kleinunternehmer, small-amount invoices up to EUR 250 and passenger tickets remain exempt.

Who is affected in 2028?

Companies whose 2026 total turnover was not above EUR 800,000 and which could therefore still use paper or — with consent — PDF in 2027.

Is a PDF no longer enough in 2028?

No. Outgoing invoices must be a norm-compliant format under EN 16931 — XRechnung or ZUGFeRD with all mandatory fields and correct tax logic.

Do I as a small company only have to act in 2028?

No. Receiving has applied since 2025. Sending has lead time — it makes sense to secure receiving first and prepare sending in good time.

How do I prepare for 2028?

Ensure receiving now, switch the invoicing system in 2027, tidy master data, generate test invoices and pilot sending before 2028.

E-invoicing obligation 2028: the roadmap for small companies