German e-invoicing for trades: the 2026, 2027 and 2028 deadlines

Receiving and issuing are separate obligations

A supplier sends XML while a homeowner wants a readable invoice and a business client specifies a format. In Germany, domestic businesses, including small businesses under the Kleinunternehmer rules, have needed to be able to receive e-invoices since 1 January 2025. An email mailbox is generally sufficient for receipt, but review and retention need a process. See the German Finance Ministry FAQ.

Which transactions are covered?

The general VAT requirement concerns supplies between businesses established in Germany where the customer purchases for its business. Certain exempt transactions are excluded. A repair for a private homeowner is not brought into B2B e-invoicing merely because it is construction work. Separate invoice obligations for property-related services still need checking. The basis is § 14 UStG.

Small-business supplies have an issuing exception under § 34a UStDV. Invoices up to €250 gross may qualify for the small-amount rule under § 33 UStDV, but that rule does not apply to, among other cases, § 13b reverse-charge supplies. Check the actual transaction.

Transition through 2028

§ 27(38) UStG provides the following general transitions:

• Through 31 December 2026, invoices for 2025 and 2026 supplies may still use paper or, with recipient consent, another electronic form such as an ordinary PDF.
• During 2027, this option continues to year-end for 2027 supplies if the issuer's previous-year total turnover did not exceed €800,000.
• From 2028, those general transitions end for covered domestic B2B transactions; statutory exceptions remain.

Certain EDI procedures have their own transition through the end of 2027. Emailing a PDF is not EDI. Review the relevant total turnover with accounting; one project's turnover is not the threshold test.

A PDF alone is not an e-invoice

Structured, machine-processable data is required. XRechnung and suitable ZUGFeRD profiles are common formats. For hybrid ZUGFeRD, inspect the embedded XML, not only the visible PDF. Read the format comparison.

Public-sector customers have separate rules. B2B transitions do not provide blanket permission to email an authority a PDF. Check federal supplier guidance and the specific state or municipal recipient.

Prepare the office

Classify private, business and public customers; choose a receiving mailbox and deputy; retain original XML or the complete hybrid document; check supplier, scope, quantities, number and amounts; test the actual final output with the recipient; and document who resolves questions, approves and confirms handover.

Hassolux organises quotations and invoices with customers and projects. Check the actually issued file: a preview or demo is not proof of the final e-invoice format. Continue with project invoices, accounting preparation, help and plans.

As of 6 October 2026; these German rules do not automatically apply elsewhere.