E-invoice from 2027: who has to issue them now

Since 1 January 2025, all companies in Germany must be able to receive e-invoices. For issuing them there has been a grace period so far. For many companies it ends on 31 December 2026. From 1 January 2027, companies with a total turnover of more than €800,000 in 2026 must send their invoices to other domestic companies as e-invoices. From 2028 this applies to everyone.

Contents: What applies from 2027 · Timeline · Exemptions · Travel expenses · BMF letter 2026 · Checklist · Spesenfuchs

What applies from 1 January 2027

An e-invoice is an invoice in a structured electronic format that software can read automatically. It must comply with the European standard EN 16931. In Germany these are mainly XRechnung (pure XML) and ZUGFeRD from version 2.0.1 (PDF with embedded XML, not in the MINIMUM and BASIC-WL profiles). A normal PDF, a scan or a photo is not an e-invoice but an “other invoice”.

The obligation applies to supplies between companies that are both established in Germany. Invoices to private individuals are not affected.

The timeline until 2028

From	What applies
1 January 2025	All companies must be able to receive e-invoices.
1 January 2027	Issuing is mandatory with a total turnover in 2026 of more than €800,000.
1 January 2028	Issuing is mandatory for all companies.
30 June 2030	End of the simplification for final invoices after down-payment invoices.

Until the end of 2027, companies with a turnover of no more than €800,000 may still write paper or PDF invoices. The threshold refers to the total turnover of 2026. If you were just above it in 2026, you are in from January 2027.

What does not have to be an e-invoice

Some receipts are permanently exempt and may still come on paper or as a PDF:

• Small-amount invoices up to €250 gross, for example restaurant, petrol station or car park
• Tickets for passenger transport, for example train tickets
• Invoices from small businesses (Kleinunternehmer)
• Invoices to private individuals and certain tax-exempt supplies

What this means for travel expenses and expenses

For most travel receipts, little changes. Train tickets are tickets for passenger transport, the coffee on the road or the lunch under €250 is a small-amount invoice. These receipts continue to come as paper, photo or PDF.

It is different for larger invoices to your company: a hotel invoice of €480 for three nights, a business meal with customers of €320 or the invoice from a seminar provider will increasingly reach you as e-invoices from larger providers from 2027. From 2028 this applies to all providers. For you to deduct the input tax, the invoice must be made out to your company.

For entertainment the following still applies: you must also record the occasion and the participants so that the costs are recognised as a business expense. More on this in our guide Post entertainment receipts correctly.

In future, your employees will often receive e-invoices by e-mail as a file. For the travel expense report in Spesenfuchs, submit e-invoices in ZUGFeRD format (PDF with embedded XML), not as a printout. The structured part of the invoice is what counts.

New in the BMF letter of 15 October 2026

On 15 October 2026, the German Federal Ministry of Finance published a third letter on e-invoicing. It supplements the letters of 2024 and 2025. The most important points according to the analyses of specialist publishers and tax firms:

• Final invoices: down payments already made may be deducted in a simplified way until 30 June 2030.
• Attachments: an attachment must be embedded in the e-invoice. A second file in the same e-mail is not enough.
• Description of the supply: the structured part must clearly state what was delivered or performed. A reference to a contract is not sufficient.
• Consequences: anyone who sends a PDF instead of a mandatory e-invoice does not commit an administrative offence. However, the recipient’s input tax deduction may be at risk.

We compare the XRechnung and ZUGFeRD formats in the article E-invoice formats in comparison.

Checklist for your company

1. Check turnover 2026: if it is above €800,000, the obligation applies from January 2027.
2. Check your invoicing software: can it create XRechnung or ZUGFeRD?
3. Clarify receipt: a fixed e-mail address for incoming invoices makes allocation easier.
4. Think of travel expenses: employees should submit e-invoices as a file, not as a printout.
5. Involve your tax advisor: clarify how the data goes to accounting or to DATEV.

E-invoices in Spesenfuchs

Spesenfuchs processes e-invoices in ZUGFeRD format. Upload the file in the receipt inbox, up to ten files at once. The receipt data is taken over and the receipt is ready for the report. After approval, the original PDF with the embedded XML goes to DATEV, Lexware Office, sevdesk and the other connected programs, including with the DATEV file export. More on the page E-invoice in Spesenfuchs.

Sources: § 27 (38) UStG, § 14 UStG, § 33 UStDV, § 34 UStDV, BMF letters of 15 October 2024, 15 October 2025 and 15 October 2026