E-invoicing: from 1 January 2027 the paper deadline ends for businesses above 800,000 euros in turnover
An expert article in IT-Finanzmagazin dated 15 September 2026 is a reminder that the German obligation to issue e-invoices in B2B takes effect on 1 January 2027. It applies to companies with more than 800,000 euros of prior-year turnover; from 1 January 2028 it applies to everyone. The legal basis is the Wachstumschancengesetz (German growth opportunities act), the format benchmark is the European standard EN 16931.
What happened
On 15 September 2026 IT-Finanzmagazin published an article on the state of e-invoicing and e-reporting in Europe and pointed to the German cut-off date: on 1 January 2027 the transition period for issuing invoices in domestic B2B business ends for companies with more than 800,000 euros of prior-year turnover. Businesses below that threshold may continue to work on paper or with PDFs until 31 December 2027; from 1 January 2028 the issuing obligation applies to everyone. The legal basis is the version of the German VAT act as amended by the Wachstumschancengesetz (German growth opportunities act); only a structured format in line with the European standard EN 16931 counts as an e-invoice, in practice XRechnung or ZUGFeRD from version 2.x. The obligation to receive such invoices has already been in force since 1 January 2025 with no transition period. Exemptions include small-value invoices up to 250 euros gross, travel tickets and services provided by small businesses under the Kleinunternehmer rules. The article places this in the European context: France brought the first stage into force on 1 September 2026, Slovakia follows on 1 January 2027, and the driver is the EU initiative ViDA.
Who it affects
Every business with B2B turnover above 800,000 euros — meaning most retail companies with several branches, wholesalers, catering businesses, trade businesses with commercial customers and practically every restaurant that invoices corporate hospitality. Pure consumer business at the till is not affected; the receipt stays the receipt.
Assessment
The real damage does not arise at the point of sending, but at the money. Anyone who sends a PDF invoice to a business customer from January 2027 when an e-invoice would be required is handing that customer an invoice that makes their input VAT deduction contestable. The customer will notice, their tax adviser at the latest, and then the invoice is not paid but queried. A question of form turns into a payment term of 60 days instead of 14. That is why this deadline is not an IT question but a liquidity question.
Second point that many underestimate: the threshold is measured on prior-year turnover, so what counts is the current year 2026. Anyone who ends 2026 just above 800,000 euros is in scope on 1 January 2027, without ever having received a notification. And anyone who assumes their till or merchandise management system handles it automatically should check rather than assume. In the same corner sit the two other deadlines heading for the same business: the planned obligation to offer a digital payment option from 2027 and the draft till legislation with a target date of 2028. Three initiatives, one till position — and still three separate projects on the desk.
What to do now
- Check your own 2025 B2B turnover and extrapolate the current 2026 figure — that number alone decides whether 1 January 2027 or 1 January 2028 applies.
- Get written confirmation from your merchandise management or accounting provider that it can issue XRechnung or ZUGFeRD 2.x, and by which date. A verbal promise in a support chat is not confirmation.
- Tidy up the receiving side: one fixed invoice email address that somebody empties daily, and an archive in which the XML file is stored, not just the visual rendering.