Germany confirmed its 2027 e-invoicing date and split its suppliers in two
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On 15 October 2026 the German finance ministry published a third letter on the obligatory electronic invoice and left the statutory dates alone. Suppliers with more than €800,000 of turnover in 2026 must issue structured invoices from 1 January 2027, and the rest from 2028.
Price Double Check works by email on whatever arrives: the invoice, the price list it should have been billed on, and a reply naming the lines where the two disagree. A mandate settles the form of a document and says nothing about the figure on it, and what these German dates change for a buyer is narrow.
What the letter of 15 October does
It is the third application letter on the subject, reference III C 5 - S 7287-a/00019/021/017, and it supplements the two that came before it on the same date in 2024 and 2025. It amends the VAT application decree on the duty to use an electronic invoice, on the mandatory content of one, and on how a structured invoice is corrected. It does not touch the timetable.
It also closes a gap that the previous two opened. An electronic invoice issued up to 31 December 2026 which satisfies the earlier letters but not the new guidance will not be objected to, deduction of input tax included. For a buyer that matters in one narrow way: documents received this quarter are not going to be withdrawn and reissued in a different shape.
The timetable, as the statute has it
| From | Who | What applies |
|---|---|---|
| 1 January 2025 | Every business established in Germany | Able to receive a structured invoice. This part was never deferred: only the duty to issue one was |
| Until 31 December 2026 | Every issuer | A paper or other invoice remains allowed for supplies performed by that date |
| 1 January 2027 | Issuers whose total turnover in 2026 was above €800,000 | A structured invoice on the European semantic model, for domestic supplies to other businesses |
| Until 31 December 2027 | Issuers at or below €800,000, and EDI arrangements that cannot carry the required content | The older forms stay allowed for one more year |
| 1 January 2028 | Everyone in scope | No transition left |
The obligation runs between businesses established in Germany, where establishment means a seat, a place of management, a habitual residence or a German fixed establishment taking part in the supply. Sales to consumers are outside it.
What it changes for a buyer
If you buy from Germany from somewhere else in the Union, the direct answer is nothing: a cross-border supply is not a domestic one, and your supplier may keep sending the document they send now. If you buy from Germany while established in Germany, the obligation is already yours on the receiving side and has been since January 2025.
The interesting part is the year in between. The €800,000 line is drawn on a supplier's own 2026 turnover, which is not a figure any buyer knows, and the invoice carries no statement of which side of it the sender falls on. So a purchasing desk with twenty German suppliers spends 2027 receiving both forms at once, switching one supplier at a time, in an order it cannot predict.
- A supplier changing the system that issues invoices is the moment item codes and descriptions move. In the chain behind this service, 335 of 442 invoice lines carried a description that did not match its own row in the price list, and the code was the only usable key — codes that arrive with new suffixes after a migration break a comparison silently.
- The price list is not in scope of any of this. Lists arrive as spreadsheets and PDFs before the change and after it, so the structured half of the comparison gains nothing from a supplier's migration.
- A structured invoice is machine-readable and still carries whatever price its sender put into it. Which field holds that price, and what the field means, is in the six fields on a UBL invoice line.
- Receiving structured documents without an accounting system to put them in is its own small problem, and it is covered in receiving Peppol invoices without an ERP.
One practical step for the next two months: ask each German supplier when they intend to switch and whether their item codes survive the move unchanged. The second half of that question is worth more than the first, and almost nobody asks it.
In breve
- What changes on 1 January 2027 for a buyer outside Germany
- Directly, nothing. The duty falls on suppliers established in Germany invoicing other businesses established in Germany. Indirectly, some of those suppliers will move to a new invoicing system in the same weeks, and that is when their codes and descriptions are most likely to change.
- Why the two dates are a year apart
- The transition rules in the German VAT act are staggered by size. Issuers whose total turnover in the preceding calendar year was no more than €800,000 keep the old forms for a further twelve months, and so do EDI arrangements that cannot carry the content the new rules require.
Forward one invoice and the price list it should have been billed on, in whatever form each of them arrives in, and the comparison comes back by email naming the lines that differ — structured document or scanned PDF, the arithmetic is the same. What a check costs is on the home page.