E-invoice obligation in Germany 2027: what sellers need to know

You have had to be able to receive e-invoices since 1 January 2025. You must issue them for supplies made from 1 January 2027 if your total turnover last year was above 800,000 euros, and for supplies made from 1 January 2028 if not. This covers invoices to other businesses in Germany, not invoices to private customers.

Last updated: October 27, 2026

In brief

Receiving: applies since 1 January 2025 to all domestic businesses, small businesses included.
Issuing: in 2027 only if last year's total turnover was above 800,000 euros; from 2028 for everyone.
Private customers: no e-invoice duty, also not on Amazon or eBay.

Which dates apply to you?

You sell on Amazon or eBay and wonder whether every invoice needs a new format in 2027. For most sellers the deadline arrives in 2028, because their total turnover in the previous year stays below 800,000 euros. The transition rule is in section 27 (38) UStG:

Supply made	Issuing an invoice	Receiving an e-invoice
1 January 2025 to 31 December 2026	E-invoice; an other invoice only if you transmit it by 31 December 2026 (paper any time, a PDF by e-mail only with the recipient's consent)	must be possible
1 January 2027 to 31 December 2027	E-invoice; another invoice only if your total turnover last year was at most 800,000 euros and you transmit it by 31 December 2027	must be possible
from 1 January 2028	E-invoice	must be possible

Two details people often miss:

What counts is when the supply was made, not the invoice date; on top of that there is a cut-off date for transmission. For supplies in 2025 and 2026, section 27 (38) no. 1 UStG allows an other invoice only if it is transmitted by 31 December 2026. A paper or PDF invoice that you send only in January 2027 for a delivery made in December 2026 is no longer covered by this rule.
Total turnover under section 19 (2) UStG is the yardstick for the 800,000 euros. It is the issuer's turnover of the previous year, so for 2027 your 2026.

For invoices exchanged through electronic data interchange (EDI) that are not already e-invoices, a further transition period runs to the end of 2027.

Who is covered, who is not?

The duty applies only if you have to issue an invoice at all, to another business for its business, and only if both sides are established in Germany (section 14 (2) sentence 2 no. 1 UStG). Established means: seat, management or a permanent establishment involved in the supply in Germany; without a seat, your residence or habitual abode counts.

You do not have to issue an e-invoice for:

invoices to end consumers (B2C),
small amounts up to 250 euros gross (section 33 UStDV), except for supplies where the recipient owes the VAT (section 13b UStG, section 33 sentence 3 UStDV),
supplies by small businesses (section 34a UStDV),
supplies to legal entities that are not businesses, such as many associations,
many tax-exempt supplies under section 4 nos. 8 to 29 UStG.

If a small business switches to the standard scheme, the duty applies to it from that point. More: E-invoices for small businesses.

What does it mean for Amazon and eBay sellers?

Most of your orders go to private customers. There is no e-invoice duty for them; for a delivery of goods you usually do not have to issue an invoice, but you may (exception: a distance sale from another EU country into Germany without OSS, section 14a (2) UStG). It is different for orders from business customers in Germany, for example through Amazon Business: the duty applies on the timetable above if the invoice is above 250 euros gross. If you sell to a business in another EU country that has no permanent establishment in Germany involved in the supply, the buyer is not established in Germany: for a delivery you still have to issue an invoice under section 14 (2) sentence 2 no. 1 UStG, but not as an e-invoice. The usual invoice rules apply, for example for the intra-Community supply.

A closer split into B2C and B2B is in E-invoices for online sellers, the Amazon Business cases in E-invoices for Amazon Business customers.

Which format counts as an e-invoice?

An e-invoice is an invoice in a structured electronic format that allows electronic processing (section 14 (1) UStG). A plain PDF does not qualify; it is an other invoice. The Federal Ministry of Finance (BMF) names XRechnung and ZUGFeRD from version 2.0.1 as formats that meet the requirements, except the ZUGFeRD profiles MINIMUM and BASIC-WL. The difference between the two is in XRechnung or ZUGFeRD: which fits you?, the technical side in Creating and validating XRechnung and ZUGFeRD e-invoices.

What exactly applies during the transition?

Until the duty applies to you, you may issue an other invoice. Paper always works. Another electronic format, for example a PDF by e-mail, only with the recipient's consent (section 14 (1) UStG). If a file meant as an e-invoice has format errors, it does not meet the requirements and counts as an other invoice (BMF letter of 15 October 2025, margin no. 6a). Validation is not a condition for tax recognition, but the BMF recommends it when you create and send the invoice.

How long do you keep e-invoices?

Eight years, incoming and outgoing invoices (section 14b (1) UStG). For an e-invoice at least the structured part must be kept intact in its original form. How to read and store incoming files is in Receive and read e-invoices.

Common mistakes

Fixing the deadline to the invoice date. What counts is when the supply was made.
Assuming 2027 applies to everyone. Up to 800,000 euros total turnover last year, the transition rule still applies in 2027.
Treating a PDF as an e-invoice. A plain PDF is an other invoice.
Forgetting about receiving. Small businesses also have to be able to receive e-invoices; an e-mail inbox is enough for that.
Mixing up private and business customers. The duty depends on the recipient.

How VAT GPT helps

If you soon have to send e-invoices to business customers, you can create them in VAT GPT: in the invoice editor you choose the output format "ZUGFeRD (PDF)" or "XRechnung (XML)" and download the file. VAT GPT reads incoming e-invoices when you upload them. If you upload your Amazon and eBay reports first, the OSS return and the VAT return, your most important duties, are in one place; with VAT GPT Pro you send them on. There is Free, Go (30 days free with all Pro features) and Pro (€49 per month or €444 per year, including VAT). Try for free now

Frequently asked questions

Do I have to issue e-invoices in 2027? For supplies from 2027, if your total turnover last year was above 800,000 euros. Otherwise from 2028.

Do I have to receive e-invoices already? Yes, since 1 January 2025. An e-mail inbox is enough for receiving.

Do I need an e-invoice for private customers? No. The duty does not apply to invoices to end consumers.

Is a PDF enough? Until the end of your transition period yes, if the recipient agrees; after that no. A plain PDF is not an e-invoice.

Does it apply to invoices to companies abroad? The duty under section 14 (2) UStG requires issuer and recipient to be established in Germany.