E-invoicing for SMEs: what do I have to change by when?

Since 2025, companies in Germany must be able to receive e-invoices. From 2027 most must also issue them. What that means in practice, which formats are sufficient and how to switch without project weeks.

E-invoicing for SMEs: what do I have to change by when?

What an e-invoice is — and what it is not

An e-invoice is an invoice in a structured electronic format that complies with the European standard EN 16931. In Germany that means two formats in practice: XRechnung (pure XML) and ZUGFeRD from version 2.x (a PDF with an embedded XML file). Both can be processed by software without retyping.

A PDF invoice sent by e-mail is not an e-invoice. Since 2025 it counts as an “other invoice” — just like paper. This is the most common confusion in conversations with clients: anyone still sending PDFs has not switched.

Which deadlines apply

The obligation applies to transactions between German businesses (B2B). Invoices to consumers are not affected.

Since 1 January 2025 every business must be able to receive and archive e-invoices. An e-mail address and a storage location are enough; the recipient no longer has a right to refuse.

Until 31 December 2026 businesses may still issue invoices on paper or as PDF if the recipient agrees. From 1 January 2027 the e-invoice is mandatory — with one exception: businesses with prior-year turnover up to €800,000 may continue issuing other invoices until 31 December 2027. From 1 January 2028 the issuing obligation applies to everyone.

Small businesses under section 19 UStG are exempt from issuing but must be able to receive e-invoices. Low-value invoices up to €250 and travel tickets remain exempt.

The switch in four steps

First: sort out receiving. A fixed e-mail address for incoming invoices and a storage location that keeps the file unchanged and readable for ten years. With us this runs through the Client Portal — the XML goes straight into the books.

Second: check issuing. Most invoicing, merchandise and trade-business systems can now generate XRechnung or ZUGFeRD. Ask the vendor for the “EN 16931” profile and have a test invoice generated.

Third: define the process. Who issues invoices, who checks incoming invoices, who approves. That belongs in the GoBD process documentation — one paragraph is enough if it is correct.

Fourth: set a cut-off date. Whoever switches by the end of 2026 avoids queries from customers who will no longer accept PDFs from January.

What changes in the accounting

With structured invoices, retyping disappears. Invoice number, amount, tax rate and due date are machine-readable in the file and are pre-posted automatically. The query list we send monthly gets shorter; the management report is ready earlier.

For mandates that already submit documents digitally through the portal, nothing changes in the workflow — only the file format.

How this looks in your business is quickest to clarify in the initial consultation. Book an initial consultation.

Frequently asked

What clients ask us beforehand

Your question is not here? Call or write to us. You get an answer, not a brochure.

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Usually not. First check whether your existing software supports the EN 16931 profile. If not, free generators that output XRechnung are sufficient for small volumes.

The invoice is not considered proper for VAT purposes. The recipient may lose the input-tax deduction and reject the invoice. Fines are not currently provided for; the risk lies in the customer relationship.

Ten years in the original format, i.e. the XML or ZUGFeRD file itself — a printout is not enough.

Contact

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Initial consultation free of charge. Reply within one working day. T +49 541 3502005.

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