E-Rechnung Mandate 2027: All Deadlines at a Glance — and What They Really Mean for B2B Merchants

The E-Rechnung mandate (Germany's e-invoicing requirement) arrives in stages: since January 1, 2025, all German B2B companies must be able to receive E-Rechnungen. From January 1, 2027, companies with prior-year revenue above €800,000 must also issue E-Rechnungen — from January 1, 2028, that applies to everyone. Paper and simple PDF invoices are definitively over in B2B.

The deadlines in detail

The rules are based on the Wachstumschancengesetz (German Growth Opportunities Act, § 14 UStG — the German VAT Act). Here is the complete roadmap:

Three details that are frequently overlooked in practice:

The €800,000 threshold refers to prior-year revenue. What counts is your 2026 revenue, not the current year. Anyone with a strong 2026 is included from January 2027 immediately — that hits more mid-sized companies than the "large companies first" framing suggests.

The transition period until the end of 2027 only covers issuing. Receiving structured E-Rechnungen was never postponed. Anyone who receives an XRechnung today and only has PDF workflows is already operating outside the rules.

Small businesses are not exempt. They merely have longer for issuing, until the end of 2027. From 2028 the obligations apply without exception.

What an E-Rechnung is — and what it isn't

An E-Rechnung is a structured, machine-readable invoice conforming to the standard EN 16931. In Germany there are two formats:

• ZUGFeRD — PDF with embedded XML data (hybrid: human-readable + machine-readable)
• XRechnung — pure XML file, the standard primarily for public administration and large companies

We've broken down the differences between the two formats in detail — which one is mandatory for whom and why they aren't competitors — in ZUGFeRD vs. XRechnung.

What is not an E-Rechnung: a simple PDF, a scan, an email with an invoice attachment. Even a PDF invoice sent by email doesn't meet the requirements — it contains no structured data.

What does this mean for your B2B sales?

At most companies, invoicing runs through ERP or accounting — DATEV, Lexware, or similar systems largely solve the E-Rechnung topic on their own. Anyone already invoicing digitally is well positioned for the issuing transition.

But the E-Rechnung mandate has a consequence that goes beyond accounting: it presupposes structured data. A line-item-accurate, machine-readable invoice can only exist if the underlying processes deliver structured data.

Concretely, that mainly affects the order chain:

• Pricing logic: If customers have different prices — tiered pricing, customer groups, special terms — that logic has to be stored in the system. Manually "remembered" special prices and Excel lists on the side cause discrepancies between order and invoice that show up immediately with structured invoices.
• Order data: What your customer ordered has to land on the invoice line by line. The further apart order intake (phone, email, fax) and invoicing are, the more translation work — and the more sources of error.

The E-Rechnung mandate is therefore a good occasion to think one step further: anyone who has to touch processes anyway can use the opportunity to digitalize sales too — not just the invoice, but the entire path from order to invoice. The effort isn't greater, the benefit much higher.

Two ways to implement the mandate

ERP-driven: The ordering system delivers structured order data, accounting creates the E-Rechnung in the ERP. A proven path for companies with an established ERP landscape. What matters is that the data flows electronically — not through double entry.

Integrated: One system covers ordering and invoicing. The E-Rechnung is created directly from the order data — no interfaces, automatically consistent. For mid-sized merchants without a complex ERP, usually the faster path. What a B2B online shop costs on the integrated path is calculated here.

Kontorly follows the integrated approach: customer groups and tiered pricing are core features, orders run digitally, and E-Rechnungen (ZUGFeRD and XRechnung) are created directly from the order data. If your business customers shouldn't just receive invoices but order themselves in an order portal, that's the consistent path.

Checklist: What you should do now

1. Check receiving: Can your accounting process ZUGFeRD and XRechnung files? Best to test with a real sample file.
2. Determine your own deadline: Was your 2026 revenue above €800,000? Then January 1, 2027 applies to you. Otherwise January 1, 2028 — plan a buffer anyway.
3. Audit your ordering processes: How do your customers order today? Where do the prices live? Answers like "Excel," "phone," or "sales knows" show you where the transition work is.
4. Decide on an architecture: ERP-driven or integrated — both work, but the decision should be made deliberately, before the deadline presses.

FAQ

From when exactly does the E-Rechnung mandate apply?

For receiving, since January 1, 2025. For issuing, from January 1, 2027 with prior-year revenue above €800,000, and from January 1, 2028 for all domestic B2B revenue.

Does the mandate also apply to small businesses?

Yes, from 2028 without exception. Small businesses merely have longer for issuing, until the end of 2027.

What exactly is an E-Rechnung?

A structured, machine-readable invoice per EN 16931 — as ZUGFeRD (PDF with embedded XML) or XRechnung (pure XML). A simple PDF isn't enough.

Who issues the E-Rechnung — my shop or my accounting?

That isn't prescribed. In practice, the ERP or accounting usually invoices. What matters: the order data must be handed over to invoicing in structured form. A system that covers both saves the interface effort.

What happens in case of violations?

Invoices that aren't E-Rechnungen can constitute regulatory offenses — fines up to €5,000 per invoice are possible. On the recipient side, the input VAT deduction can also be at risk.

Does the mandate also apply to B2C sales?

No, sales to private consumers are exempt. Many merchants switch anyway to unify processes.

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This article is based on the Wachstumschancengesetz (§ 14 UStG) and the official FAQ of the Federal Ministry of Finance. The law and the BMF letter are legally binding — for your individual case, consult your tax advisor.