German BMF Confirms: No Postponement of 2027 E-Invoicing Sending Mandate
The German Federal Ministry of Finance (BMF) has officially confirmed that the 1 January 2027 e-invoicing sending mandate for businesses with revenue above €800,000 will not be postponed. Businesses have eight months to prepare.
The Bundesministerium der Finanzen (BMF) — Germany's Federal Ministry of Finance — has issued an official statement confirming that the 1 January 2027 e-invoicing sending mandate will proceed as scheduled.
The mandate requires all German B2B businesses with annual revenue exceeding €800,000 to issue structured e-invoices (XRechnung or ZUGFeRD EN 16931 profile) for all domestic transactions from that date.
Why the Confirmation Matters
Despite Germany's relatively smooth 2025 receiving mandate rollout, a small minority of industry associations and business groups had publicly advocated for a one-year postponement, citing:
- Complexity for mid-market companies without dedicated IT departments
- Software vendor support gaps for some legacy systems
- Concerns about customer acceptance
The BMF's April 2026 statement dismisses these concerns directly, noting that:
- Software support is available: Over 85% of German SME accounting software already supports XRechnung 3.0 and ZUGFeRD 2.3 generation, per a survey by Bitkom (Germany's digital industry association, March 2026)
- Receiving infrastructure is in place: German businesses have had since January 2025 to configure receiving — their suppliers should now be able to send without additional customer-side configuration
- The threshold covers the large majority of B2B invoice volume: Businesses above €800,000 represent approximately 15% of German B2B entities but over 75% of total B2B invoice value
What the 2027 Mandate Requires
From 1 January 2027, businesses with 2025 annual revenue above €800,000 must:
- Issue XRechnung (UBL or CII format) or ZUGFeRD 2.3 (EN 16931 or XRechnung profile) for all domestic B2B invoices
- Ensure the format passes the KoSIT validator
- Retain invoices in GoBD-compliant archiving for 10 years
PDF invoices remain legally valid for receiving (there is no obligation on the buyer to refuse them) but are no longer an acceptable sending format for mandated businesses.
The 2028 Universal Mandate Remains Unchanged
The BMF also confirmed the 1 January 2028 mandate — which extends the sending obligation to all remaining German businesses regardless of size — is also on track.
What Businesses Should Do Now
If your 2025 revenue was above €800,000: 1. Confirm your accounting software generates XRechnung 3.0 or ZUGFeRD 2.3 EN 16931 2. Validate a sample invoice via the KoSIT online validator 3. Set a go-live date for switching — the BMF recommends October 2026 at the latest 4. Communicate the switchover date to your major B2B customers
Source
BMF Schreiben (official statement) on e-Rechnung, April 2026: bundesfinanzministerium.de
