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Recht & Compliance

E-invoicing mandate 2027: rebuild your invoice flow

From 2027 issuing becomes mandatory: how businesses link incoming and outgoing invoices into the ERP without media breaks, instead of forwarding PDFs by email.

13 min read E-RechnungXRechnungZUGFeRDRechnungsprozessMittelstand

In many companies the e-invoicing mandate is treated as a legal topic: a new format, a deadline, an obligation to be met somehow. The other view is more useful in practice. The change is first of all a question of workflow — how an invoice enters the business, how it is checked and posted, and how an outgoing invoice is created without anyone retyping figures or forwarding a PDF by email. Approach it that way and you meet the obligation as a by-product while dropping the manual work that used to sit between the inbox, the ERP and accounting. Over 51 million (DATEV) e-invoices processed in the first half of 2026 alone show that the switch is well under way — and that a business still sending pictures of invoices will soon be the exception. This article describes the invoice flow from receipt to the issuing mandate on 1 January 2027 and beyond, without splitting legal hairs, but with the dates that matter. How we support such a changeover in a project is set out under interfaces.

Key takeaways

  • The e-invoice is not a format change for accounting but a workflow change for the whole business: a structured invoice can be read, checked and posted by the system, a PDF cannot — the gain is in the flow, not in the file.
  • Every domestic business has had to be able to receive e-invoices since 1 January 2025 (Federal Ministry of Finance). Issuing them is phased in: from 2027 above 800,000 EUR prior-year turnover, from 2028 for all the rest (Growth Opportunities Act).
  • Since 2025 a plain PDF has legally counted as an other invoice, not an e-invoice (German VAT Act, section 14). Sending one is still permitted for now, but it is the path that is being phased out — not the one to keep investing in.
  • The expensive part is never producing the XML but the media break before and after it: retyping incoming invoices and manually gathering the outgoing data. That is exactly where the changeover pays off, if it is to be more than ticking a box.
  • Almost everything can be prepared without time pressure: check which system holds invoices, set up an inbound channel, choose the outgoing format and settle the handover to accounting. Get that in order in 2026 and 2027 brings a routine, not a deadline.

In a business an invoice is not a document you file but a case that passes through several hands. An incoming invoice is received, checked for accuracy, matched to an order or cost centre, approved, paid and archived. An outgoing invoice is created from an order, a delivery or a service rendered, gets the right line items, prices and tax rates, is sent out and has to be found again later. At each of these stations many companies still rely on manual work today — and that manual work, not the paper or the postage, is the real cost block.

The difference between a PDF and a structured e-invoice lies not in appearance but in machine readability. A PDF is a picture of a document; a program sees no amounts there, only pixels. A structured e-invoice to EN 16931 (EN 16931) contains the same details as machine-readable data fields: invoice number, date, supplier, line items, net, tax, payment terms. That lets the system read an incoming invoice itself and propose it to accounting instead of someone copying the figures. The entire benefit of the change hangs on this one point: data instead of a document image.

So for a business that treats it as a workflow topic, the 2027 deadline is good news rather than a burden. It forces you to look at the invoice path in full — from which system creates the invoice to how it reaches accounting without a second capture. Lay that chain out cleanly once and you gain an effect that goes beyond the obligation: fewer typing errors, faster approvals, cleaner figures. The jump from 64 million (DATEV) e-invoices across all of 2025 to over 51 million in the first half of 2026 alone is not an administrative detail but a sign of a switch that has arrived in mid-size companies.

The three dates that matter

Receiving: since 1 January 2025 every domestic business must be able to accept structured e-invoices in B2B trade — no consent from the sender is required for that any more (Federal Ministry of Finance). Sending, first stage: from 1 January 2027 businesses with more than 800,000 EUR turnover in the previous year must issue their domestic B2B invoices in a structured format (Growth Opportunities Act). Sending, second stage: from 1 January 2028 the obligation to issue applies to all remaining businesses (Growth Opportunities Act). Until the end of 2026 other invoices such as PDF or paper may still be sent with the recipient's consent (Federal Ministry of Finance).

What applies from when — and to whom

The obligation covers domestic transactions between businesses (B2B). Invoices to private customers (B2C), to recipients abroad and small-value invoices up to 250 EUR (section 33 VAT Implementing Ordinance) are not covered; travel tickets also stay outside. That sounds like a lot of exceptions but changes little about the basic direction: anyone who regularly invoices other businesses cannot avoid structured invoices, and anyone already receiving supplier invoices today is already receiving e-invoices — whether their own workflow is ready for it or not.

The split between receiving and sending matters. Receiving has been mandatory for everyone, regardless of size, since the start of 2025. That is where many businesses are unknowingly behind: they can technically accept an XRechnung, but nobody reads it in a structured way — the file is printed out or filed as an attachment, and the manual work remains. For sending, the previous year's turnover decides the cut-off date. Anyone above 800,000 EUR in 2026 issues from 2027; everyone else has a year longer (Growth Opportunities Act).

This staggering tempts smaller businesses to defer the topic to 2028. From a workflow point of view that is a mistake. Start only at your own cut-off and you settle the inbound path, the outgoing format and the accounting handover under time pressure — usually just when suppliers have long been invoicing in a structured way and your own inbox is full of files nobody processes automatically. The effort does not shrink by waiting; it only becomes more urgent. The German Retail Federation points out that a considerable part of the mid-size sector is not as far along with the changeover as the deadlines suggest (German Retail Federation).

AspectPDF by email (other invoice)Structured e-invoice
What the recipient getsA picture of the documentMachine-readable data fields to EN 16931
Further processingRetyping or text recognition neededSystem reads line items directly
Legal status from 2025Other invoice, not an e-invoice formatMeets the e-invoicing obligation
Source of errorsTransfer errors during captureNo second capture, no typing errors
ArchivingFiled as a file, searched by filenameStructured, found via invoice data
Future viabilityFading out as a sending routeThe route that remains

Receiving invoices without a media break

Receiving is the part often overlooked because no deadline looms here — the duty to receive has applied for a while. That is exactly why the most unused potential sits here. In many companies an incoming XRechnung lands in the mail inbox, is opened, the figures are eyeballed and typed by hand into accounting or the ERP. That turns a machine-readable invoice back into manual work — the most expensive possible way to handle the new format. A clean inbound path takes the file automatically, reads the fields and presents them for checking. How far such routine back-office work can be taken off people's hands is covered in AI in the back office.

The first step is a fixed inbound channel instead of many personal inboxes. A central invoice address that collects incoming e-invoices is the basis for them being processed by machine at all. The second step is reading them out: from the structured file, supplier, invoice number, line items and amounts are taken over as a data record. The third step is the accuracy check — matching against order and delivery note — which only becomes automatable thanks to the available data. How a business builds such handovers without capturing twice is shown in eliminating duplicate data entry.

A central invoice address captures incoming e-invoices instead of spreading them across personal inboxes. Only then is there a single point where automatic reading can happen at all.

At the end of this path comes archiving, and for e-invoices that is no side point. The structured file is the original that counts for tax and must be kept unchangeably — a printout does not suffice, and leaving the original only in the mail inbox is not orderly filing. What to watch for is covered in GoBD-compliant document storage; the concrete periods are the topic of meeting retention periods digitally. For storing the machine-readable documents in the business, orderly document digitisation is the right frame.

Sending: XRechnung and ZUGFeRD from your system

For sending, the decisive question is not which format you choose but where the data comes from. A structured invoice is created most cleanly where the order and delivery data already sits — in the ERP or the order system. Create the invoice there and customer, line items, prices and tax rates are already present and need not be entered a second time. Type it into a separate program and then export it as a file, and you create exactly the media break the e-invoice is meant to abolish.

Two formats meet the EN 16931 requirement. XRechnung is plain XML — a structured file without a visible layout, meant for system-to-system processing and widespread in business with public-sector clients. ZUGFeRD is a hybrid: a PDF that looks readable to the human eye, with the machine-readable data embedded invisibly. For many businesses ZUGFeRD is the more comfortable entry point, because the recipient still sees a familiar document while the system gets the data anyway. Both are permitted; the choice depends on the recipients and on what your own system can produce.

XRechnung: pure data

A structured XML without its own layout. Ideal for system-to-system processing and widespread in business with public-sector clients. Anyone sending many invoices to the same recipients benefits from direct processing.

ZUGFeRD: PDF with data

A visible PDF with invisibly embedded data fields. The recipient sees a familiar document, the system still reads the values. Often the more comfortable entry point for mixed recipient groups.

Source: the leading system

The invoice is created where order and delivery sit — in the ERP or the inventory system. Line items, prices and tax rates are present and are not entered a second time.

A printout stays possible

A preview or a printout for your own eyes is still allowed. The structured file is what counts; the readable document is an addition, not the original.

A short look at the data makes tangible what this is about. What is a line with an amount to a human is a set of named fields to the system, which it can process without guesswork. The following, heavily shortened example shows not the full format but only the principle: the same invoice, but as a readable structure instead of a picture.

Simplified example: structured invoice data (principle to EN 16931, shortened)
<Invoice>
  <InvoiceNumber>2027-000142</InvoiceNumber>
  <InvoiceDate>2027-01-15</InvoiceDate>
  <Supplier>Sample Business Ltd</Supplier>
  <Line>
    <Description>Maintenance plant A, January</Description>
    <Quantity>1</Quantity>
    <UnitPrice>480.00</UnitPrice>
    <TaxRate>19</TaxRate>
  </Line>
  <Net>480.00</Net>
  <Tax>91.20</Tax>
  <Total>571.20</Total>
  <PaymentDue>2027-01-29</PaymentDue>
</Invoice>

# No retyping: the system reads number, amounts and due
# date straight from the fields and proposes the posting.
# With a PDF the same line would have to be captured by
# hand or via text recognition.

Connecting to accounting and the ERP

The real gain appears at the seam between systems. An e-invoice that is created but then typed into accounting by hand again has missed half its purpose. What makes sense is a handover in which the invoice data flows from the leading system into accounting and produces a posting proposal there. Whether that happens over a direct interface, a structured handover file or a document transfer to the tax office depends on the setup — the goal is the same in every case: no second capture of the same figures.

The cost calculation behind it is simple. Every document captured by hand costs a few minutes and carries a risk of error; over a year and many documents that adds up to a fixed amount that recurs every month. A handover built once, by contrast, costs once and then carries without further manual work. How to run that calculation for your own business is shown in what a single case really costs and interface or manual work. For structured merging of invoice, order and payment data, clean data integration is the frame.

  • An inbound channel that accepts incoming e-invoices centrally and reads them out automatically, instead of spreading them across personal inboxes.
  • An outgoing format — XRechnung or ZUGFeRD — created from the leading system in which order and delivery already sit.
  • A handover to accounting that turns the invoice data into a posting proposal and does not demand a second capture.
  • Audit-proof storage of the structured original file, with retention periods in mind.
  • A clear handling of exceptions: invoices abroad, to private customers and small amounts still follow their own rules.
  • A named responsibility for who looks after the invoice flow when a file does not run through cleanly for once.

Format and input VAT deduction

In the longer run the proper format decides input VAT deduction: where an e-invoice is mandatory, in principle only the structured invoice entitles you to deduct. During the current transition the tax authority does not object to a still-permitted other invoice at the recipient (BMF letter, 15 October 2024). That is no reason to defer the topic — it is the reason to build the inbound path now so that structured invoices arrive and are checked cleanly. Assessing the individual case belongs in tax hands; this article does not replace tax advice.

Resistance and typical worries in the business

In daily practice the changeover rarely meets fundamental objections but concrete worries. The most common: our invoicing program can already do this, why the effort? Almost every current system can indeed receive and issue — the question is whether the invoice moves on without a media break or whether it is retyped afterwards. The second worry concerns recipients: what if a customer cannot process the structured invoice? For mixed recipient groups ZUGFeRD is the answer, because the visible PDF stays readable to the human while the data travels along.

A third worry is the fear of a large project. It is usually unfounded once you break the path down: receiving can be ordered independently of sending, and sending can be trialled on one recipient group before being extended to all. That is exactly the point of a sober process analysis: record today's invoice path, name the break points and split the change into steps that can be delivered one at a time. Plan a series of small steps instead of one big push and you reach the goal more calmly — checking at each step whether it holds. Where individual departments take on small building blocks of the change themselves, low-code in the business is worth a look.

The deadline forces a question nobody otherwise asks: how does an invoice actually move through our business? Answer it honestly and you usually find more manual work than you expected — and that is exactly what can be switched off now.

Project experience

What a business can prepare now

The larger part of a successful changeover lies in preparation, and that costs no money at first, only clarity. Four questions go a long way: which system creates the outgoing invoices today and what structured formats can it produce? Where do incoming invoices go and who processes them? In which format should outgoing invoices leave in future, measured against the recipients? And how does the data reach accounting or the tax office without a second capture? Settle those four points in 2026 and 2027 brings a routine, not a deadline.

It also helps to take an honest inventory of the media breaks. Often it turns out that the invoice path is only one of several where the same data is touched more than once — quote, order, delivery note, invoice. Where a change is due anyway, it is worth looking at the whole chain; spotting media breaks in your company helps with that inventory. And whatever runs on permanently after the change — looking after the invoice flow, small adjustments, handling faults — belongs in orderly operations and not in the remaining time of a project phase.

  1. Check which system creates the outgoing invoices and which structured formats it can output.
  2. Set up a central inbound channel for e-invoices so that incoming documents can be read automatically at all.
  3. Choose the outgoing format: XRechnung for system-to-system processing, ZUGFeRD for mixed recipient groups.
  4. Settle the handover to accounting or the tax office so that no document is captured a second time.
  5. Set up audit-proof storage of the structured original files and account for the retention periods.
  6. Trial the change on one recipient group or invoice type before extending it to the whole business.

The early start is the cheap start

Begin in 2026 and you have no cut-off date on which something has to work, but a routine that is bedded in by then. The inbound path can be ordered today without any deadline, because the duty to receive applies anyway and suppliers have long been invoicing in a structured way. Change the outbound side one invoice type at a time and you spread the effort while keeping control at each step. The difference between a calm and a hectic transition lies not in ability but in the timing of the first step.
This article is based on data from: DATEV (e-invoices processed in 2025 and the first half of 2026), the Federal Ministry of Finance and the Growth Opportunities Act (deadlines and thresholds of the e-invoicing obligation), the German VAT Act and its Implementing Ordinance (definition of the e-invoice, small-value threshold), the BMF letter of 15 October 2024 (transitional rules), the European standard EN 16931, the German Retail Federation and our own project experience from changeovers in mid-size companies.

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