E-invoicing deadlines: which invoice is still allowed when
Choose the year of supply, the invoice form and last year’s turnover: the calculator says whether this invoice is allowed and until which date the transition covers it.
This invoice form is
Only with the customer’s consent
Transitional rule until 31 December 2027.
| 2025 | Only with the customer’s consent |
| 2026 | Only with the customer’s consent |
| 2027 | Only with the customer’s consent |
| 2028 on | No longer allowed |
What counts is the year of the supply, not the invoice date (section 27(38) UStG). Consent can be given implicitly (Finance Ministry letter of 15 October 2025, para. 22).
Prepared by Radif Partners · Method · VAT Act, ministry letters and XRechnung 3.0.2 checked on 25 October 2026
The transition period for German e-invoicing is set out in section 27(38) of the VAT Act (UStG) and has three numbers. Under number 1 you may still issue a paper invoice for supplies up to 31 December 2026 or, with the customer's consent, an invoice in another electronic format such as PDF. Number 2 extends this to supplies made in 2027, but only for businesses whose total turnover in the previous year was no more than €800,000. Number 3 allows invoices via an EDI procedure until 31 December 2027 if the recipient agrees, even where the format does not follow the EN 16931 standard. In all three cases what counts is the year in which the supply was made, not the invoice date. A supply made in December 2026 may therefore still be invoiced as a PDF in January 2027. The general invoicing deadline applies regardless: for supplies to businesses, the invoice must be issued within 6 months of the supply.
The three numbers of the transition
The e-invoicing deadlines are not in section 14 UStG itself but in the application rule section 27(38) UStG. It allows a departure from the new rule for a limited time. Each of its three numbers has its own conditions:
- Number 1: supplies up to 31 December 2026. Paper is allowed and, with the recipient’s consent, another electronic format such as PDF. It applies to every business, with no turnover limit.
- Number 2: supplies in 2027. The same forms remain allowed, but only if the issuer’s total turnover in the previous year was no more than €800,000.
- Number 3: supplies up to 31 December 2027. An invoice by EDI is allowed with the recipient’s consent, even if the data does not follow EN 16931. More on EDI invoicing.
After that only the e-invoice remains, except for the permanent exceptions such as small-amount invoices, travel tickets and invoices from small businesses. You may send an e-invoice voluntarily in any year; since 2025 it no longer needs consent, because every business must accept it.
Five typical cases
The rules look simple until a supply runs across the turn of the year. These cases show how the numbers work together:
The agency with high turnover. An advertising agency was well above €800,000 in 2026. For supplies until the end of 2026 it still sends PDF invoices to customers who have agreed. For every supply from January 2027 it must issue an e-invoice; number 2 does not help it.
The trade business below the limit. A painting firm stayed below €800,000 in 2026. Throughout 2027 it may still write paper invoices or, with consent, PDF invoices. From January 2028 the e-invoice applies to it as well.
The supply in December. A consultant finishes a project on 15 December 2026 and invoices in January 2027. The year of supply, 2026, decides, so number 1 applies: the PDF stays allowed, even though the consultant’s turnover is above the limit.
The wholesaler on EDI. A wholesaler has exchanged EDIFACT messages with a retail chain for years. With the chain’s consent it may carry on until the end of 2027, whatever its turnover. From 2028 its EDI format must be able to map the EN 16931 data completely, or it switches to XRechnung or ZUGFeRD.
The business lunch for 180 euros. A restaurant gives a business customer a receipt for an amount below the small-amount limit. Small-amount invoices have no deadline; they may stay on paper or PDF permanently.
When the €800,000 threshold counts
The limit refers to total turnover within the meaning of section 19(3) UStG, not to profit and not to the turnover with a single customer. For invoices of 2027 only the year 2026 matters. A business founded during 2026 counts the actual turnover of that short year. Whether your business falls under the mandate at all is what the general check tests:
Issue e-invoices from
Issue e-invoices from
1 January 2028
| Be able to receive e-invoices | Required since 1 January 2025 |
| Paper or PDF (with consent) until | 31 December 2027 |
| EDI without EN 16931 until | 31 December 2027 |
| Always allowed on paper or as PDF | Small amounts up to €250, tickets |
Invoicing deadline and corrections
Besides the transition periods, the general deadline in section 14(2) UStG applies: invoices to businesses must be issued within 6 months of the supply. It is not an e-invoicing deadline, but it explains why supplies of the old year are still invoiced in the new one around the turn of the year. A correction can always be made as an e-invoice. What a wrong form can lead to is explained on consequences of a missing e-invoice.
You need not obtain consent to the PDF for every single invoice. The Finance Ministry letter of 15 October 2025 accepts an agreement or tacit acceptance. Switching now saves duplicate work in 2027: the invoice creator produces e-invoices without software of your own.