← Back to Blog
e-rechnungzugferdrechtkmuJune 26, 2026 · 6 min read
StandardSimply explained

E-Rechnung 2028 Part 1: Who Has to Comply, and When?

PDF → XML · EN 16931 · RECEIVE 2025 · ISSUE 2028 · 8Y ARCHIVE
Editorial illustration: on the left a dissolving PDF whose pixels reorder into a structured XML data set on the right; behind it the checkpoints 'RECEIVE 2025' and 'ISSUE 2028', an EN 16931 checklist and an '8Y' archive safe. Status lines: visible invoice image optional, machine-readable data mandatory.Editorial illustration: on the left a dissolving PDF whose pixels reorder into a structured XML data set on the right; behind it the checkpoints 'RECEIVE 2025' and 'ISSUE 2028', an EN 16931 checklist and an '8Y' archive safe. Status lines: visible invoice image optional, machine-readable data mandatory.

It started as a side question. I had built an invoicing portal for a client, and while planning the next steps it suddenly surfaced: do we actually need to worry about the E-Rechnung? And from when?

A quick note before we go further: in Germany, the move toward a mandatory structured invoice goes by the name “E-Rechnung”. It’s a legal concept, not just a file format, so I’ll keep the German term throughout.

The short answer made me pause for a moment myself. For receiving these invoices, the obligation has applied to every company since the start of 2025. And for issuing them, a deadline is creeping closer that many still comfortably assume is far off.

This first part sorts out the legal framework, before the following parts get into meeting it cleanly in technical terms. One word up front: I’m a developer, not a tax advisor. What follows is checked against the official sources, but it doesn’t replace advice for your specific case.

A PDF Is No Longer an Invoice

The sentence sounds absurd at first, but it hits the core. An invoice you attach to an email as a PDF is, in the sense of the new rules, not an E-Rechnung. It’s a “sonstige Rechnung” (an “other invoice”), and that is only allowed for a transitional period.

A real E-Rechnung is not a picture of an invoice, but a structured dataset that software can process further without any retyping. The visible image is optional, the data is mandatory. This is exactly where the familiar PDF parts ways with what is ultimately required.

Receiving and Issuing Are Two Different Obligations

This is the most important distinction in the whole matter, and it’s where most people get muddled.

Receiving E-Rechnungen has been mandatory for every domestic company since the start of 2025. No transition period, no exception, including small businesses, including anyone who only sends paper themselves. Legally, a normal email inbox is enough for that. And the sender no longer needs your consent to send a standard-compliant E-Rechnung. They may send it to you, and you have to be able to accept it and make it readable. Anyone without a way to do that already has a problem today.

Issuing is the other half, and this is where the staggered timeline comes in. It applies to invoices between domestic companies, so to B2B business:

  • Since 2025. The obligation applies in principle. Paper stays allowed; a PDF you may only send if the recipient agrees.
  • Through end of 2026. Everyone may still issue paper or PDF. This is where we are right now, and this window closes at the turn of the year.
  • Through end of 2027. The grace period only extends for smaller issuers whose revenue in the prior year, 2026, was below €800,000.
  • From 2028. No more grace period. Whoever issues a B2B invoice issues it as an E-Rechnung. For everyone, with no further exception.

The legal basis is the rewritten Section 14 of the German VAT Act (Umsatzsteuergesetz), introduced with the Growth Opportunities Act (Wachstumschancengesetz). The underlying EN 16931 standard derives from European rules; the whole thing was most recently spelled out in a letter from the German Finance Ministry in October 2025. The most practical source for everyday use is the German Finance Ministry’s e-invoicing FAQ.

Who’s Out, and Who’s Only Half Out

Before every sole trader panics: there are clear exemptions.

Private customers. Invoices to end customers, so B2C, are entirely exempt. The salon billing a client for a treatment is not affected by this. An E-Rechnung to private individuals is only permitted with their consent.

Small businesses. Anyone using the small-business scheme (Kleinunternehmer) is permanently exempt from issuing, even after 2028. But a small business must still be able to receive, since 2025, just like everyone else.

Small amounts. Invoices up to €250 gross and travel tickets may still run as a “sonstige Rechnung”. So nothing changes for the coffee-to-go receipt.

And this is exactly where the question became real for my portal. The invoices it generates don’t go to private customers, but to a business customer. That’s B2B. So this invoice stream falls under the genuine obligation, by 2028 at the latest. The topic was no longer academic for me, but a concrete, dated assignment.

Keeping It for Eight Years

Generating an E-Rechnung is one thing. Storing it correctly is another. The structured dataset has to be archived unchanged for eight years, in the original, machine-readable. A plain PDF filing of the pretty visual part is not enough; the data core is what matters. Anyone who today collects invoices only as a printed PDF in a folder is building themselves a gap for later.

Why Starting Early Pays Off

You could push the whole thing to 2027. It’s tempting, because formally nothing has to happen before then. Three reasons argue against it anyway.

First, the comfortable window for the broad mass closes as early as the end of this year; from 2027, only the revenue threshold counts. Second, business customers, especially larger organizations, often want the structured invoice sooner than the law forces it, because their own accounting has long run on it. Third, switching over under time pressure and the threat of penalties is the worst way to go about it.

For me, that settled it: I wanted to make the portal E-Rechnung-ready now, not scramble in 2027. The next question was then the genuinely interesting one. Do I take a finished solution off the market and plug it in, or do I solve it myself, and properly? That’s the subject of Part 2.

Part 1 of 4 in the E-Rechnung 2028 series.

E-Rechnung 2028 Part 2: Plug In a Library, or Build It Right? →

The engine from this series is a project: Rechenwerk.