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e-rechnungzugferdrechtkmuJune 26, 2026 · 4 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 with a side question. I had built an invoicing portal for a client. A small web app that creates and sends invoices. And at some point the question came up: do we actually need to worry about the E-Rechnung?

The answer made me pause for a moment myself.

One thing up front, because it matters: I’m a developer, not a tax advisor. What follows is checked against the official sources. It does not replace advice for your specific situation.

A PDF Is No Longer a Valid Invoice

The sentence sounds absurd at first. But under Germany’s new rules, an invoice you attach to an email as a PDF does not count as an E-Rechnung. It only counts as an “other invoice”, and that will soon no longer be allowed.

So what is a real E-Rechnung? Not a picture of an invoice. Not a nicely formatted PDF. It is a structured dataset. Data in a fixed order that software can read and process without anyone having to retype a single number.

Think of it this way: a PDF is like a photo of a form. Looks fine, but a computer can do very little with it. An E-Rechnung is like a filled-in spreadsheet where every cell has its fixed place. The computer knows instantly where the total is, who the sender is, which tax rate applies.

In Germany two formats count as a real E-Rechnung. Both meet a European standard called EN 16931, which defines what information must be included. One is called XRechnung and is a pure dataset. The other is called ZUGFeRD and embeds the same dataset inside a visible PDF. A plain PDF by itself, a photo, or a Word file do not count.

Receiving and Issuing Are Two Different Things

This is the most important distinction in the whole matter.

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. A regular email inbox is legally sufficient. And the sender no longer needs your consent. They may send you an E-Rechnung, and you have to be able to accept it and make it readable.

Issuing is the other half. Here the timeline is staggered. It applies to invoices between businesses, so when one company bills another.

  • Through end of 2026. Everyone may still issue paper or PDF. This is where we are right now. The window closes at the turn of the year.
  • Through end of 2027. The grace period only extends for smaller businesses whose revenue in the prior year was below 800,000 euros.
  • From 2028. No more grace period. Whoever bills another business does so as an E-Rechnung. For everyone, no further exception.

Who Is Out, and Who Is Only Half Out

Before every sole trader panics: there are clear exemptions.

Private customers. Invoices to end customers are entirely exempt. A salon billing a client for a treatment is not affected. This is B2C (business to consumer), and it stays outside the obligation.

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

Small amounts. Invoices up to 250 euros gross may still run as a simple invoice. Nothing changes for the coffee-to-go receipt.

And this is exactly where the question became real for my portal. The invoices it generates do not go to private customers. They go to a business customer. That is business-to-business. So this invoice stream falls under the genuine obligation, by 2028 at the latest.

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 its original form, machine-readable. It is not enough to just file the pretty visual part as a PDF. The data core has to stay intact.

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. Tempting, because formally nothing has to happen before then.

Three reasons argue against it anyway. First, the comfortable window for the broad majority closes at the end of this year. From 2027, only the revenue threshold matters. Second, business customers, especially larger organizations, often want the structured invoice sooner than the law forces it, because their own accounting already runs 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 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? That is 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? →