Transition periods 2025–2028
German e-invoice transition periods 2025–2028: what applies when
Short answer: the receipt obligation for structured e-invoices has applied in domestic B2B since 1 Jan 2025. For issuing, there are phased transition periods: paper and (with consent) other formats such as PDF remain allowed for a while — through end of 2026 for everyone, through end of 2027 for smaller businesses. From 1 Jan 2028 all domestic B2B issuers must in principle issue structured e-invoices per EN 16931.
The timeline at a glance
- Since 1 Jan 2025 — structured e-invoice allowed (no recipient consent needed). Paper & other formats still possible with consent. Receiving structured e-invoices is mandatory.
- Through 31 Dec 2026 — for sales up to end of 2026, paper or another electronic format (e.g. PDF, with consent) remains allowed.
- 2027 — smaller issuers (previous-year 2026 turnover ≤ €800,000) may still use paper/other formats with consent. Larger ones must issue structured e-invoices; EDI procedures remain allowed under conditions.
- From 1 Jan 2028 — structured e-invoice (EN 16931) for all domestic B2B issuers; compliant/extractable EDI procedures allowed.
Receiving vs issuing — the key distinction
The transition periods only concern issuing. For receiving there is no grace period: since 1 Jan 2025 domestic B2B recipients must be able to accept and process structured e-invoices. If you still rely on plain PDFs, sort out the receiving side first — regardless of how long you may still issue differently. More on the receiving side: receiving German e-invoices.
The €800,000 threshold for 2027
For sales executed in 2027 there is an extra relief for smaller businesses: if total turnover in the previous year (2026) did not exceed €800,000, paper or other electronic formats (with recipient consent) may still be issued. Businesses above that threshold must issue structured e-invoices in 2027; established EDI procedures remain allowed under conditions, provided the required data can be extracted in EN 16931-compliant form.
What the transition periods do not mean
- No pause on the receiving side. You must be able to accept structured e-invoices since 2025 — there is no deadline for that.
- A PDF is still not an e-invoice. Even where a PDF is temporarily allowed, it counts as an "other invoice", not a structured e-invoice. See why a PDF is not an e-invoice.
- No guaranteed consent. Issuing in another format requires the recipient's consent — they may insist on the structured e-invoice from now on.
Prepare instead of waiting
The deadlines move the date, not the task. Being able to generate and validate EN 16931-compliant files early avoids last-minute stress before 2028 — and lets you already send structured e-invoices to recipients who ask for them. fakturai builds a ZUGFeRD/Factur-X or XRechnung file from your data and checks it against a KoSIT-aligned accept gate before delivery. Validate an existing file for free, with no account.
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What fakturai does not replace
This page summarises the statutory transition periods for orientation and is not legal or tax advice. Individual cases, special rules and the concrete application to your business should be clarified with your tax advisor. fakturai checks and generates the technical format and structural compliance per EN 16931 with a KoSIT-aligned accept gate; it makes no legal, tax or delivery guarantees.
Next step
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Related: German e-invoicing mandate · Receiving German e-invoices · ZUGFeRD vs XRechnung vs EN 16931 · E-invoicing for small businesses