The staged plan, short and clear
Receiving: everyone since 2025. Sending, staged: until the end of 2026 transition with consent, from 2027 a sending obligation for companies above EUR 800,000 prior-year turnover, from 2028 for everyone else in domestic B2B.
So 2028 is not a new starting point but the end of the last grace period for sending.
Who exactly is affected in 2028
Affected are the smaller companies that in 2027 were still below the EUR 800,000 threshold and were therefore allowed to send paper or PDF longer. From 2028 this possibility falls away.
Even those who are small today should not dismiss this as “far off”. Preparation needs lead time, and 2028 comes faster than the year number sounds.
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 in the right profile, 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 in advance than under time pressure at the end of 2027.
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.
- 2026/2027: check the invoicing/ERP system for norm-compliant sending.
- Before 2028: tidy up master data, generate test invoices.
- Before 2028: pilot the sending process, inform customers.
- Ongoing: keep an eye on thresholds and deadlines.