Germany is introducing e-invoicing in stages, and the most important stage is approaching fast. Since 1 January 2025, German businesses have had to be able to receive electronic invoices. On 1 January 2027, the obligation to send them follows for businesses with more than 800,000 euros in turnover. Summaries of e-invoicing in Germany in 2027 often suggest it also applies to Dutch suppliers. Whether it does depends on where you are established.

The three dates

The rules come from the Wachstumschancengesetz and are detailed in letters from the German Federal Ministry of Finance (most recently 15 October 2025):

  • 1 January 2025: all businesses in Germany must be able to receive e-invoices. Sending on paper or as a plain PDF remains allowed during the transition.
  • 1 January 2027: businesses with turnover above 800,000 euros in the previous year must send e-invoices.
  • 1 January 2028: the obligation applies to all businesses. Those below the threshold in 2027 may keep using other invoice formats until 31 December 2027.

The 800,000 euro threshold refers to the sender’s turnover in the previous calendar year. It is not an amount per invoice, and it is not your customer’s turnover.

What counts as an e-invoice

A PDF sent by email is not an e-invoice. The invoice must be in a structured, machine-readable format that complies with the European standard EN 16931. In Germany, that comes down to two formats:

  • XRechnung: a pure XML invoice.
  • ZUGFeRD (in its EN 16931 variant): a PDF with embedded XML, which stays readable for people too.

Does this apply to you as a Dutch supplier?

The German obligation applies to domestic B2B transactions between businesses established in Germany. If you are established in the Netherlands and have no establishment in Germany, you are not obliged to send German e-invoices. Having a customer in Germany is not enough to trigger it.

Something still changes in practice. German customers are setting up their administration around structured invoices and increasingly ask the same of their suppliers. Meeting that is a commercial choice, not an obligation. If you do have a German establishment or a German VAT number with which you make domestic sales, have your tax adviser confirm whether you fall under the rules.

What you can arrange now

If you are covered, or want to keep serving German customers smoothly, this order helps:

  • Work out your 2026 turnover, and so whether you are first in line on 1 January 2027 or a year later.
  • Check whether your invoicing system can create XRechnung or ZUGFeRD, and not only a PDF.
  • Ask your larger German customers which format and channel they expect.
  • Make sure customer data is correct: VAT number, address and references. With a structured invoice, a wrong field means rejection, not a phone call.

Start at the source of your invoice data

A structured invoice is never better than the system it comes from. Our Billing Platform creates invoices directly from Salesforce, in the right language and template per customer, so invoice lines match the order. For how the transition looks in other countries, read our articles on e-invoicing in Belgium, France and the Netherlands.

Want to know what 1 January 2027 means for your invoicing process? Get in touch and we will walk through your situation together.