The €800,000 threshold: who must issue e-invoices in Germany from 2027
By evoicely · Last checked 20 October 2026
If your total turnover (Gesamtumsatz) in the previous calendar year was above €800,000, your domestic B2B invoices for supplies made from 1 January 2027 must be e-invoices. At or below €800,000, you may keep sending paper invoices, or PDFs if your customer agrees, for supplies made in 2027. From 1 January 2028 the threshold no longer matters: every business established in Germany issues e-invoices to other German businesses. The rule is in § 27 (38) of the German VAT Act (UStG).
What the law says
Germany's e-invoice obligation applies to supplies made after 31 December 2024. § 27 (38) UStG lets invoice issuers postpone it in three cases (§ 27 UStG):
| Supplies made in | Who may still use paper or another format | Condition |
|---|---|---|
| 2025–2026 | Every invoice issuer | Invoice sent by 31 Dec 2026. A non-e-invoice electronic format such as a PDF needs the customer's consent; paper doesn't. |
| 2027 | Issuers whose total turnover in the previous calendar year was not more than €800,000 | Invoice sent by 31 Dec 2027. Same consent rule. |
| 2027 | Every issuer using EDI (as defined in Commission Recommendation 94/820/EC) | Invoice issued by 31 Dec 2027, with the customer's consent. |
| 2028 onwards | Nobody | Domestic B2B invoices must be e-invoices, apart from the exemptions below. |
The Federal Ministry of Finance (BMF) says the same in its FAQ: with a previous-year turnover of up to €800,000, the transition period runs until the end of 2027 (BMF FAQ on the e-invoice, question 11). The details are in the BMF letter of 15 October 2024 (BStBl I p. 1320, paragraphs 62 to 65), supplemented by letters of 15 October 2025 and 15 October 2026.
Which turnover counts
The test uses the Gesamtumsatz as defined in § 19 (2) UStG, the same figure used for the small-business scheme (§ 19 UStG). It is:
- the sum of your taxable supplies within the meaning of § 1 (1) no. 1 UStG,
- calculated on the payments received (not on invoices sent),
- minus certain VAT-exempt supplies listed there (for example, exempt financial and property transactions that are only ancillary to your business),
- and leaving out sales of fixed assets.
It is not your revenue figure from Stripe or your accounts. Which of your sales count, for example services to customers abroad, is worth checking with your tax advisor. The law also doesn't say how the threshold applies within a VAT group (Organschaft); ask your advisor if that applies to you.
Which year decides
The law refers to the turnover "in the preceding calendar year", and the BMF calls it the previous-year turnover (Vorjahresumsatz). For supplies in 2027, that is your 2026 turnover. You'll only know the final figure early in 2027, so if you're close to €800,000, plan for e-invoices from January either way.
Three examples
All three are fictional German SaaS companies selling subscriptions to German businesses.
| Company | Gesamtumsatz | Invoices for 2027 supplies |
|---|---|---|
| SaaS A | 2026: €650,000 | May still be PDFs (with the customer's consent) or paper until the end of 2027. E-invoices from supplies in 2028. |
| SaaS B | 2026: €1,200,000 | Must be e-invoices from 1 January 2027. |
| SaaS C | 2025: €900,000; 2026: €780,000 | Like SaaS A: only 2026 counts for 2027, so the transition still applies. |
The dates follow the supply, not the invoice. A subscription period that ends in December 2026 but is invoiced in January 2027 falls outside the 2025–2026 rule, which requires the invoice to go out by 31 December 2026. Check cases like that with your advisor. The BMF letter of 15 October 2026 (paragraph 2) does confirm that advance and partial invoices sent before your obligation starts don't have to be e-invoices, even if the supply and payment come later (BMF letter, 15 October 2026).
Exemptions, whatever your turnover
According to the BMF FAQ (question 4), an invoice doesn't have to be an e-invoice for:
- small-amount invoices up to €250 gross (§ 33 UStDV);
- tickets that count as invoices (§ 34 UStDV);
- supplies by small businesses under the Kleinunternehmer scheme (§ 34a UStDV);
- supplies to legal entities that aren't businesses, such as many associations or public bodies. Invoices to public authorities follow their own e-invoicing rules (see Leitweg-ID).
The mandate only covers invoices between businesses established in Germany. Invoices to consumers and to customers abroad are out of scope.
Receiving doesn't depend on the threshold
Since 1 January 2025, every business established in Germany must be able to receive e-invoices, including small businesses under the Kleinunternehmer scheme. The BMF says an email inbox is enough (FAQ, questions 8 and 12).
What counts as an e-invoice
Structured data following EN 16931: in practice XRechnung or ZUGFeRD from version 2.0.1, in the BASIC profile or higher (EN 16931 recommended). A PDF on its own isn't one. See XRechnung vs ZUGFeRD and ZUGFeRD profiles for which ones count.
If you bill with Stripe
Stripe Invoicing creates invoices and PDFs but doesn't generate XRechnung or ZUGFeRD files itself (Stripe docs). Above the threshold, you need that extra step for German B2B customers by January 2027. Below it, you have until January 2028, but your customers may ask for e-invoices sooner, because their software can process them automatically. Germany's e-invoicing mandate for Stripe users walks through the steps, and Does Stripe support e-invoicing? compares the options.
evoicely turns your Stripe invoices and credit notes into ZUGFeRD (EN 16931) and XRechnung, each checked with the official KoSIT validator. Get started, free for 10 e-invoices a month.
This is general information, not legal or tax advice. Check what applies to your business with your tax advisor.