E-invoicing obligation 2025/2026: who, what, when

E-invoicing obligation 2025/2026: who must do what, and when

The e-invoicing obligation has applied since 2025 — but in stages, and that is exactly what causes confusion. Who has to receive, who has to send, from when? A clear sorting that also clears up the most common misconception.

Author: OzyCore GmbH · Editorial teamCreated: Apr 24, 2026Updated: Oct 11, 2026

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 and supplemented them with a second letter of 15 October 2025.

So much for the theory. The confusion only starts at “from when, for whom”.

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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: if the supplier sends an e-invoice, you must accept it. An e-mail mailbox is enough for this; the tax authorities do not require a separate mailbox just for e-invoices.

This is the acute, often underestimated part of the obligation. There is no grace period to invoke here.

Sending: the staged schedule

For sending, transition rules apply (§ 27 (38) UStG). Until the end of 2026 every company may still issue an “other invoice” instead of an e-invoice: paper is always allowed, a PDF or another electronic format only with the recipient's consent. In 2027 this applies only to companies whose total turnover in the prior year was no more than EUR 800,000; EDI procedures remain allowed for everyone in 2027 with consent. From 1 January 2028 the e-invoice is mandatory for everyone in domestic B2B.

Permanently exempt are small businesses under the Kleinunternehmer scheme (§ 34a UStDV), small-amount invoices up to EUR 250 (§ 33 UStDV) and passenger tickets (§ 34 UStDV) — other invoices may still be issued for these. But Kleinunternehmer must receive e-invoices too.

What you really must do now

Sorted by urgency (as of October 2026):

Now: be able to receive e-invoices safely (fixed address, validation, original archive).
Now: keep the XML original unchanged, not just a PDF.
By the end of 2026: check your own total turnover for 2026 — above EUR 800,000 means e-invoices from 1 January 2027.
Now: switch your invoicing system to norm-compliant sending (mandatory from 2027 or 2028).
Throughout: keep receiving and sending mentally separate.

Frequently asked questions

Since when does the e-invoicing obligation apply?

Since 1 January 2025. Receiving in domestic B2B has been mandatory since then with no transition period; sending is staged.

Do I already have to send e-invoices?

Not necessarily until the end of 2026: paper is always possible, PDF with the recipient's consent. From 1 January 2027 companies with more than EUR 800,000 total turnover in the prior year must issue e-invoices, from 1 January 2028 everyone — except Kleinunternehmer and small amounts up to EUR 250.

Who must be able to receive e-invoices?

Every domestic company, from small-business owner to corporation — since 2025, without exception and without consent being required.

Does the obligation also apply to small-business owners?

For receiving yes, without exception. Under § 34a UStDV, Kleinunternehmer may permanently issue their own invoices as other invoices — on paper or, with the recipient's consent, as PDF.

What is the most common misconception?

Confusing receiving and sending. Sending has transition periods until the end of 2026 or the end of 2027; receiving has applied without a deadline since 2025.