Germany’s 2027 e-invoice transition: the EUR 800,000 threshold

Can you still issue a plain PDF or another non-e-invoice format for a supply performed in 2027? The key test is generally your total turnover in calendar year 2026.

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Last materially reviewed: 8 August 2026. Legal basis checked against the BMF FAQ (as of March 2026), the BMF administrative guidance, and current legislation.

Quick answer

More than EUR 800,000 total turnover in 2026: an e-invoice is generally required for in-scope supplies performed in 2027. No more than EUR 800,000: the extension can apply if the invoice is issued and transmitted by 31 December 2027.
From 2028, an e-invoice is generally required for in-scope domestic B2B transactions; statutory exceptions remain.
The extension does not affect the receiving duty or earlier recipient requirements.

Who qualifies for the extension and what does it mean in practice?

Case	Operational meaning
Supply performed in 2027; prior-year turnover up to EUR 800,000	The transition for ‘other invoices’ can apply if the invoice is issued and transmitted by 31 December 2027. From 2028, an e-invoice is generally required for in-scope domestic B2B transactions unless a statutory exception applies.
Supply performed in 2027; prior-year turnover above EUR 800,000	The turnover-based extension does not apply. The general transition ends on 31 December 2026, so an e-invoice is generally required for in-scope supplies. Permanent statutory exceptions remain.
EDI that does not yet meet the e-invoice requirements	With recipient consent, EDI that does not yet meet the e-invoice requirements may be used regardless of turnover for supplies performed in 2027 if the invoice is issued and transmitted by 31 December 2027. Qualifying EDI remains permitted afterward.
Recipient requires e-invoices earlier	A structured format can be an earlier contractual or technical requirement. That does not automatically change the statutory transition deadline.

What does total turnover mean?

The test uses statutory total turnover under section 19(2) UStG, which is not simply financial-statement or bookkeeping revenue. For a German VAT group, the total turnover of the entire VAT group is used. For self-billing (Gutschrift), use the total turnover of the customer issuing the self-billed invoice. If an independent third party issues the invoice, use the total turnover of its principal.

The EUR 800,000 test is not the turnover limit for Germany’s Kleinunternehmer VAT regime. Supplies exempt under section 19 UStG have a separate exemption from mandatory e-invoice issuance under section 34a UStDV with no statutory end date under current law. Detailed guide to e-invoicing for Kleinunternehmer

Important in practice

Even during a statutory transition, a structured format can be a contractual or technical condition of the customer’s process. Confirm and test the format, channel, and references early.

Legal sources and the full overview

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FAQ

What if my customer demands e-invoices before I am obliged?

That can be a contractual or technical delivery condition, but it is not automatically an earlier statutory duty. Agree the format and transmission route with the customer.

Can I keep sending PDF invoices if the recipient agrees?

Under an applicable transition rule or permanent exception, a plain PDF can be permitted as an ‘other invoice’. Electronic delivery generally requires recipient consent; no special form is prescribed for that consent.

Is EDI still allowed and until when?

Yes. With recipient consent, EDI that does not yet meet the e-invoice requirements may be used regardless of the EUR 800,000 threshold for supplies performed in 2027 if the invoice is issued and transmitted by 31 December 2027. Qualifying EDI remains permitted afterward.