E-invoicing in Germany: what happens in 2027 and 2028?

Germany has made electronic invoicing mandatory in three steps. Receiving is already a requirement, and issuing follows in 2027 and 2028. If you trade with German customers or suppliers, it is worth knowing when your company must be able to send and receive the right formats. The article goes through the timeline, the two main formats and what to check in Business Central before the requirements reach you.

The three steps

The dates in this article are as the rules stood in October 2026. Always check the German authority, the BMF (Bundesfinanzministerium), for the current wording, because details and transitional rules can change.

The timeline looks like this:

Since 1 January 2025: all businesses must be able to receive structured e-invoices.
From 1 January 2027: businesses with a turnover above EUR 800,000 must issue e-invoices.
From 1 January 2028: all businesses must issue e-invoices.

What counts as an e-invoice

An e-invoice in Germany is a structured, machine-readable file. A PDF that you send by email is not an e-invoice in that sense, even though it looks like an invoice on screen.

Two formats come up again and again: XRechnung and ZUGFeRD. XRechnung is pure XML. ZUGFeRD is a PDF with an XML file embedded in it, so the recipient can both read the invoice and let the system process it. In addition there is Peppol BIS 3, which is used in many places in Europe and can be sent through a Peppol access point.

What Business Central says about Germany

According to Microsoft Learn, the German localization of the E-Document framework supports Peppol BIS 3, XRechnung (UBL only) and ZUGFeRD. The page says this applies from version 26.3, so check that your environment is updated that far and that you use the German localization.

You choose the format in the Document Format field on the E-Document service. If you want to receive all three formats, you must create a separate service per format. Each document sending profile supports one format, so a customer cannot have several formats on the same profile.

Receiving ZUGFeRD is automatic: Business Central extracts the embedded XML from the PDF file and processes it as a new e-document. That the e-document is created automatically does not mean, however, that the purchase invoice is created automatically. That requires correct setup.

The practical side of issuing

Invoices to German buyers often require a buyer reference, that is, a reference number the buyer wants printed on the invoice. On the E-Document service you can decide whether the buyer reference is mandatory, and whether it is taken from the Your Reference field on the sales document or from the customer's e-invoice routing number on the customer card.

Test invoices with a customer before the deadline approaches. A format that looks right in your own system can still be rejected by the recipient.

Checklist before 2027

Determine whether your turnover means that 1 January 2027 or 1 January 2028 applies to you.
Find out which German customers require XRechnung, ZUGFeRD or Peppol.
Check the version of Business Central and the German localization.
Create E-Document services and sending profiles, and test with a customer.
Agree with an access point provider if you want to send via Peppol.

Decide what applies to you, and next steps

The EUR 800,000 threshold is decisive for whether 2027 or 2028 is your deadline. Find out which turnover counts, and which entity in the group is the sender. Business Central cannot answer that question. Your finance lead and your auditor must answer it, and the answer should be written down.

Look at the receiving side too. Since 1 January 2025, businesses must be able to receive structured e-invoices. If your German suppliers have not sent them yet, that can change without notice. Therefore check that your inbound process can handle an XML file and not only a PDF.

If you could use help setting up e-documents in Business Central, you can read about our services. We are working on an e-invoicing app for Business Central. It is an idea under development, it is not available, and it has no price or date. See the apps we are working on at the link below.