Germany's e-invoicing mandate is three dates, not one. Since 1 January 2025 every business, including every Kleinunternehmer, must be able to receive an e-invoice. From 1 January 2027 only businesses with more than €800,000 prior-year turnover must issue them. From 1 January 2028 everyone else follows, except Kleinunternehmer, who may keep issuing ordinary invoices. Most freelancers therefore have one real job this autumn: make sure your tool can receive, read and archive an XRechnung or ZUGFeRD file for eight years. A PDF does not count.
"E-Rechnung 2027" has become a marketing hook for accounting software. The date is real, but for a freelancer with €70,000 turnover it is the wrong one. The obligation that already applies to you started in 2025, and the one that will apply to you starts in 2028. Here is the timeline as the Finance Ministry publishes it, and the checklist that follows from it.
Three dates, one law
The rules sit in § 14 UStG, introduced by the Wachstumschancengesetz, with the transition periods in § 27 Abs. 38 UStG. The BMF's FAQ on the e-invoice (Stand März 2026) is the official plain-language version.
1 January 2025: receiving. Since then, "für inländische Unternehmen besteht die Notwendigkeit, eine E-Rechnung empfangen zu können." That is every business established in Germany, no size threshold. The good news from the same FAQ: "Für den Empfang einer elektronischen Rechnung genügt bereits ein E-Mail-Postfach." You do not need a portal. You do need to be able to open, read and store the file, and we get to that below.
1 January 2027: issuing, for the big ones. Until 31 December 2026, anyone may still send paper or an ordinary PDF (the PDF needs the recipient's consent). The ministry then extends that grace period: "Bei einem Vorjahresumsatz des Rechnungsausstellers bis 800.000 Euro verlängert sich diese Frist noch bis zum Ablauf des Jahres 2027." So 2027 is the year your larger clients start sending you e-invoices, not the year you have to send them.
1 January 2028: issuing, for everyone else. From then on, an invoice from one German business to another must be an e-invoice, with one standing exception.
The Kleinunternehmer exception cuts one way
If you use the small-business scheme under § 19 UStG, § 34a UStDV lets you issue a "sonstige Rechnung" (paper or PDF) indefinitely. The BMF is explicit that the exemption does not extend to receiving: "Kleinunternehmer sind zwar von der Ausstellung einer E-Rechnung ausgenommen, müssen aber dennoch in der Lage sein, E-Rechnungen zu empfangen."
Whether you should still be a Kleinunternehmer in 2027 is a separate decision, and the e-invoice is only one input. We walk through it in Kleinunternehmer or Regelbesteuerung in 2027.
What counts as an e-invoice
Not a PDF. The FAQ says it plainly: "ein einfaches PDF-Dokument fällt dann nicht mehr unter diese Definition, da es kein strukturiertes Format hat." An e-invoice is a machine-readable dataset following the European standard EN 16931. In Germany two formats do the job: XRechnung (pure XML) and ZUGFeRD from version 2.0.1 (a PDF with the XML embedded, so a human can read it too). Your accounting tool will usually offer both; ZUGFeRD is the friendlier default for clients who still print things.
Four cases stay outside the mandate: invoices up to €250 gross (Kleinbetragsrechnungen), tickets (Fahrausweise), invoices to private customers, and invoices to businesses abroad. The duty applies only between businesses established in Germany.
Archiving is the part people miss
§ 14b UStG requires you to keep a copy of every incoming and outgoing invoice for eight years (down from ten since 1 January 2025). For e-invoices the FAQ adds a condition: "Bei einer E-Rechnung ist zumindest deren strukturierter Teil so aufzubewahren, dass er unversehrt in seiner ursprünglichen Form vorliegt." Printing the ZUGFeRD PDF and filing the paper does not satisfy that. The XML has to survive untouched.
This is where an email folder stops being enough. A shared drive with a fixed naming convention is a workable minimum. An accounting tool that ingests the XML and archives it is the comfortable one.
Your checklist for this autumn
Conclusion first: for a freelancer under €800,000 turnover, nothing changes on 1 January 2027 on the sending side. Everything below is about receiving well and preparing for 2028 at your own pace.
- Mailbox. Decide which address clients send invoices to. One address, forwarded into your bookkeeping, not your personal inbox.
- Reader. Open a test XRechnung. If all you see is XML, you need a viewer or a tool that renders it. Any current freelancer accounting software does this; Accountable (affiliate link) receives, creates and archives e-invoices in both formats, and the 9am Freelancer Toolbox lists the alternatives.
- Archive. Eight years, structured part unchanged. Check where the tool stores the original file and whether you can export it if you ever switch.
- Client list. Mark which clients are German businesses (mandate applies), which are private customers or abroad (it does not), and which are likely above €800,000 (they will send you e-invoices from 2027, and may ask you to send them too as a matter of process). Only the first group matters for your 2028 switch.
- Kleinbetrag rule. Anything up to €250 gross stays as it is. Useful for the odd small job, irrelevant for your main contracts.
- Pflichtangaben. The e-invoice does not change what an invoice must contain under § 14 Abs. 4 UStG. Our checklist for writing invoices still applies, the format just gets stricter about where each field sits.
What to do on Monday
- Send yourself a test e-invoice from your accounting tool and open it in a second tool or viewer. If it fails, you have found your autumn project.
- Put the eight-year archive question to your tool provider in one email: where is the XML stored, how do I export it?
- Sort your clients into German B2B, B2C and abroad. Count the first group. That number is your 2028 workload.
- If you are a Kleinunternehmer close to €25,000 turnover, read the decision piece before year end, because the switch and the e-invoice question land together.
- Diary 1 January 2028, not 2027, as your issuing deadline, unless your prior-year turnover is above €800,000. If it is, congratulations, and your deadline is 2027.
If the invoice question has reminded you that the client list itself could be longer: a free 9am profile puts you in front of companies across DACH that hire freelancers, and every one of them will be sending e-invoices soon.
The broader picture, from Umsatzsteuer to Vorauszahlungen, is in our guide to taxes for freelancers in Germany.
This article is general information for practitioners and does not replace tax or legal advice.
