One point of standing before anything else. The binding text is the German one — the Umsatzsteuergesetz as published, and the BMF-Schreiben as issued. This page is a working guide for a reader who does not read German; where it matters, check the instrument, and where the two diverge the German text governs.
When does the Versandpflicht actually start?
| From | What applies |
|---|---|
| 01.01.2025 | Duty to receive, for every domestic business. No transitional rule, no turnover threshold, Kleinunternehmer included. |
| to 31.12.2026 | Any issuer may still send a sonstige Rechnung — on paper, or in another electronic format with the recipient's consent. |
| 01.01.2027 | Duty to issue for an issuer whose Gesamtumsatz in 2026 exceeded €800,000. |
| to 31.12.2027 | An issuer whose 2026 Gesamtumsatz was €800,000 or less may continue to send sonstige Rechnungen. Non-conformant EDI is also still permitted. |
| 01.01.2028 | E-Rechnung for all domestic B2B supplies. Every transitional rule ends. |
There is a sixth date that belongs on the same slide and is not German. Germany's mandate rests on Council Implementing Decision (EU) 2023/1551 of 25 July 2023, which authorises Germany to accept only invoices issued in electronic form by taxable persons established in the territory of Germany, and to provide that their use is not subject to acceptance by a recipient established in Germany. That authorisation applies from 1 January 2025 until the earlier of 31 December 2027 or the date on which Member States must apply national provisions transposing the amendments to Articles 218 and 232 of Directive 2006/112/EC made in the VAT in the Digital Age package.
The full mandate on 1 January 2028 therefore sits just beyond the derogation's outer limit, and what carries it from there is the general power in Council Directive (EU) 2025/516 of 11 March 2025, in force since 14 April 2025. Its new second paragraph to Article 218 allows a Member State to require electronic invoices from taxable persons established within its territory without a Council authorisation, and its amendment to Article 232 removes the need for recipient acceptance where that option is exercised. There is no gap; the legal basis hands over. But note the word both instruments use, because it decides who is caught.
Which entities in a group cross the threshold?
Two tests run in sequence, and a group tax function has to answer them in that order.
First, is the entity a domestic business at all? The BMF treats a business as domestic where it has its seat, its place of management (Geschäftsleitung), or a Betriebsstätte participating in the supply within German territory. The BMF FAQ then deals with the multinational case head on: foreign entrepreneurs who are registered for VAT in Germany but have no fixed establishment there may note that fact on the invoice in order to explain why they are not issuing an E-Rechnung. Article 11(3) of Council Implementing Regulation (EU) No 282/2011 states the same principle in general terms — holding a VAT identification number is not in itself sufficient for a fixed establishment. A group entity that registered in Germany for a distance-selling or reverse-charge reason has not thereby become an issuer.
Second, if it is domestic, what was its 2026 Gesamtumsatz? The measure is the Gesamtumsatz under § 19 Abs. 2 UStG in the preceding calendar year. That reference is itself a frequent citation error: § 19 was renumbered by the Jahressteuergesetz 2024, and older commentary still cites Absatz 3. If a German adviser or a vendor's compliance sheet cites § 19 Abs. 3, it is working from a superseded text.
Four consequences of the second test are worth spelling out for a group.
- It is measured per entity, not per group. There is no consolidated figure and no aggregation across a multinational structure. A group with €4 billion of revenue and a €600,000 German sales office is below the threshold for that entity.
- It is a cut-off value, not a running one. Whether the entity is caught on 1 January 2027 is settled by the 2026 figure alone. A system that implements the check as a live rule will make the wrong call in the boundary zone. The threshold belongs in the configuration as a dated parameter.
- It is a euro figure on German VAT rules. A group that reports the German entity in dollars or sterling, or on a management basis with a non-calendar year end, is not measuring the same number. The determination has to be made on the German VAT return basis and documented as such.
- Where a German VAT group exists, ask before assuming. Neither the statute nor the BMF material relied on here resolves how the threshold is applied inside an Organschaft. That is a question to put to German counsel with the group's actual structure in front of them, not one to settle from an English summary.
What is exempt from the issuing duty?
- Small-value invoices up to €250 gross (§ 33 UStDV)
- Travel tickets (§ 34 UStDV)
- Exempt supplies under § 4 Nr. 8 to 29 UStG
- Supplies by Kleinunternehmer under § 19 UStG — the duty to receive is unaffected
- B2C supplies
The last two are where groups most often mislabel their own entities. A dormant or very small German entity is exempt from issuing and still fully caught by the obligation to receive, which has applied since 1 January 2025 with no threshold at all.
What is legally an E-Rechnung, and what is a sonstige Rechnung?
Under § 14 Abs. 1 UStG an E-Rechnung is an invoice in a structured electronic format which is created, transmitted and received electronically, permits electronic processing, and complies with EN 16931. Everything else — paper, PDF, TIFF, JPEG, a Word file — is a sonstige Rechnung, and in electronic form it requires the recipient's consent.
This is the distinction on which most internal projects founder. A PDF sent by e-mail is not an E-Rechnung, however electronic its transmission. The BMF names XRechnung (KoSIT, currently Standard XRechnung 3.0.2) and ZUGFeRD from version 2.0.1 (FeRD, currently 2.5.2), the latter except the MINIMUM and BASIC-WL profiles, which are not complete invoices. Permitted are BASIC, EN 16931 (COMFORT), EXTENDED and XRECHNUNG. French Factur-X qualifies where it is EN 16931 conformant. The trade-offs are set out in XRechnung and ZUGFeRD.
For hybrid output the structured XML part governs. Where the PDF image diverges from it in substance, the divergence can amount to a second invoice, with a tax liability under § 14c UStG. For an automated outbound process this is a design constraint, not a warning: XML and image must be produced from one data source in one step, and not by two paths that happen to read the same master data.
What happens to EDI on 31 December 2027?
An EDI procedure that does not already meet the requirements of an E-Rechnung may, in the BMF's view, still be used until the end of 2027. From 2028 EDI survives only where its output is EN 16931 conformant. Any group invoicing German B2B counterparties through EDI today therefore has a hard deadline and a bilateral negotiation with every partner on the network — a project, not a configuration step, and one whose critical path runs through other companies' release calendars rather than your own.
How long must issued invoices be kept?
Eight years under § 14b UStG. Not ten. The period was shortened from ten to eight, and English-language coverage of the German rule gets this wrong with some consistency; so do group retention policies drafted once and applied to the German entity by default. Under the BMF-Schreiben of 15 October 2025 at least the structured part must be kept so that it is present intact in its original form. The GoBD apply in addition; storage outside a GoBD-certified system is not in itself a breach. Our register of corrections tracks the eight-year point.
In practice that means the XML has to survive byte for byte. A system that normalises the invoice on import, reformats it, or stores only the extracted fields does not meet the requirement, even where nothing is lost in substance.
Is there a German reporting system, and when?
The BMF has announced a system for near-real-time, transaction-based electronic reporting of certain invoice data to the tax administration at a later point. There is no date and no draft bill. Anyone who puts a German reporting date into a plan is working from an assumption.
The dependable anchors sit at EU level, in ViDA — Council Directive (EU) 2025/516, in force since 14 April 2025:
- 1 July 2030 — digital reporting requirements for intra-Community B2B supplies
- 1 January 2035 — existing national reporting systems must converge on the EU model
The second date is the real pacing constraint on German policy: a national system that would not converge after 2035 would be built for rework from the outset. For a group, the planning consequence is that Germany's 2027 and 2028 dates are format dates, while the reporting question is a 2030s question with a European shape.
What does a group finance function have to do differently?
A domestic German issuer and a group finance function in London, New York or Singapore face the same statute and a different problem.
- Two determinations, entity by entity. Establishment first, then Gesamtumsatz. Both are documented judgements with a date on them, and both change when the operating model changes.
- Different entities in one group start on different dates. A German manufacturing company above the threshold starts on 1 January 2027; a German service entity below it starts on 1 January 2028. A single group-wide switch date is either a year early for one or a year late for the other, and only one of those is safe.
- Intra-group flows are asymmetric. A parent established outside Germany has no issuing duty towards its German subsidiary, while that subsidiary is obliged to receive from any German supplier that sends. Designing the intra-group flow first and the third-party flow second gets this backwards.
- The archive requirement collides with group standards. A global content platform that re-renders or re-indexes on ingest will not hold the structured part intact in its original form.
- There is no state acknowledgement to rely on. Unlike the Polish and French models, Germany has no clearance step and no government-assigned invoice number, so nothing external confirms that an invoice was validly issued. Whatever evidence exists is evidence the group produced itself.
A sequence to 31 December 2026
- Determine establishment for every group entity holding a German VAT registration, and record the reasoning.
- Compute the 2026 Gesamtumsatz under § 19 Abs. 2 UStG for each domestic entity separately, in euro, on the German VAT basis.
- Fix each entity's start date as a dated constant, not as a rule that recalculates during 2027.
- Confirm that receipt genuinely works, rather than being formally established.
- Choose the outbound format: XRechnung, or ZUGFeRD from 2.0.1 in a permitted profile.
- For ZUGFeRD, prove XML and PDF are generated from one source in one step.
- Check the archive for byte-identical retention of the structured part — eight years.
- Split the inbound check into format errors, business-rule breaches and content errors instead of rejecting on any finding.
- Inventory EDI routes; they end on 31 December 2027 unless EN 16931 conformant.
- Define approval thresholds for automated outbound issuing, and record the approvals.
In practice
Where invoices are generated and released by systems or by AI-assisted workflows, the question moves from format to responsibility, and what has to be demonstrable is who or what authorised the operation before it ran. BarzelVault applies policy and approval thresholds ahead of execution and issues signed audit receipts. BarzelOps runs the cross-system workflow with durable state, approval checkpoints and tenant isolation, so each German entity's operations remain attributable to that entity.
Frequently asked questions
When must I start issuing E-Rechnungen?
From 1 January 2027 if the 2026 Gesamtumsatz exceeded €800,000; otherwise from 1 January 2028. The transitional rule for smaller issuers runs out on 31 December 2027.
Whose turnover is measured?
The individual taxable person's Gesamtumsatz under § 19 Abs. 2 UStG in the preceding calendar year. There is no group aggregation. Older commentary citing § 19 Abs. 3 is working from the pre-Jahressteuergesetz-2024 numbering.
Is a foreign parent obliged to issue an E-Rechnung to its German subsidiary?
Not where it is not established in Germany. A German VAT registration alone is not establishment; the test is seat, place of management, or a Betriebsstätte participating in the supply.
Must I already be able to receive E-Rechnungen?
Yes, since 1 January 2025, with no threshold and no transitional period. In the BMF's view an e-mail inbox is sufficient for the statutory duty.
How long must E-Rechnungen be kept?
Eight years under § 14b UStG, with at least the structured part held intact in its original form. Not ten years — that is a widespread and outdated figure.
Is there a German reporting system yet?
No. It is announced, without a date and without a draft bill. The reliable dates are the ViDA milestones of 1 July 2030 and 1 January 2035.
Where this leads
For a group, the 2027 date is not one deadline but a set of entity-level deadlines produced by two determinations that nobody outside Germany naturally owns. Establishment sits with whoever runs permanent-establishment analysis; the Gesamtumsatz sits with whoever files the German VAT return. Neither of them is usually on the e-invoicing project team, and the project cannot set its own dates until both have answered.
In practice
The control has to run before the invoice becomes irreversible.
An accepted structured invoice can be corrected but never deleted, and from the penalty date every defect has a price. Barzel puts the approval threshold, the duplicate check and the signed record in front of submission, so the process can be defended on the day an auditor or the tax authority asks.
95 days leftE-Rechnung issuing duty from 1 January 2027 for 2026 turnover above €800,000
BarzelVault
The AI action firewall: decide what an agent may do before it does it.
- Approval thresholds and policy checks enforced before execution; human approvals that expire and escalate.
- Cryptographically signed audit receipts: trigger, inputs, policy version, approver, outcome.
- Credential isolation, spend and action limits, and an emergency kill switch.
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BarzelOps
Governed workflow automation across the systems that run the business.
- Durable, idempotent execution: a timeout is retried once, never filed twice.
- Human approval checkpoints that pause the workflow and resume it.
- Isolation per entity or client, signed evidence receipts and a portable manifest; HubSpot, Xero, Gmail, Google Drive and Slack.
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Enterprise: written quote by email within two business days. No sales call.
Related
- The obligation to receive, in force since 1 January 2025
- XRechnung and ZUGFeRD: formats, profiles and cross-border pitfalls
- Workflow automation
- AI governance
- Glossary of regulatory and technical terms
Sources
- § 14, § 14b, § 14c, § 19 Abs. 2, § 27 Abs. 38 Umsatzsteuergesetz (UStG) — gesetze-im-internet.de.
- § 33 und § 34 Umsatzsteuer-Durchführungsverordnung (UStDV) — Kleinbetragsrechnungen, Fahrausweise.
- BMF-Schreiben vom 15.10.2024, III C 2 - S 7287-a/23/10001 :007. No live official URL; the Schreiben of 15 October 2025 supplements it and does not replace it.
- BMF-Schreiben vom 15.10.2025, III C 2 - S 7287-a/00019/007/243, Einführung der obligatorischen elektronischen Rechnung bei Umsätzen zwischen inländischen Unternehmern ab dem 1. Januar 2025.
- BMF, FAQ E-Rechnung, Stand 23.03.2026 — definition of inländisches Unternehmen, foreign entrepreneurs without a fixed establishment, eight-year retention.
- KoSIT, Standard XRechnung — current version 3.0.2.
- FeRD, ZUGFeRD / Factur-X — current version 2.5.2.
- Council Implementing Decision (EU) 2023/1551 of 25 July 2023 authorising Germany to derogate from Articles 218 and 232 of Directive 2006/112/EC; applies from 1 January 2025 to the earlier of 31 December 2027 or the ViDA transposition date.
- Council Directive (EU) 2025/516 of 11 March 2025 (VAT in the Digital Age), in force since 14 April 2025.
- Council Implementing Regulation (EU) No 282/2011 of 15 March 2011, Article 11.
- EN 16931 — European standard for electronic invoicing, published by CEN. Not linked: the standard is sold, not published openly.
This article is a working guide for English-speaking readers and does not constitute tax or legal advice. The binding text is the German one.