Since 1 January 2025, every business in Germany has had to be able to receive e-invoices. You must issue e-invoices for supplies to other domestic businesses that you carry out after 31 December 2026 if your total turnover (Gesamtumsatz) in 2026 was above €800,000; all other businesses follow for supplies after 31 December 2027. A business with €2 million in total turnover is therefore covered from 1 January 2027. For paper and PDF invoices covering supplies made in 2026, the transition rule only applies if they are transmitted by 31 December 2026. (As of 20 October 2026)

An AI can prepare and check quotes and invoices along the way. Binding prices, terms and the act of sending should stay in your hands.

E-invoicing mandate from 2027: the timeline

Under § 14(1) UStG (German VAT Act), an e-invoice is an invoice “issued, transmitted and received in a structured electronic format”. A PDF or a sheet of paper is an “other invoice” (sonstige Rechnung). The transition periods are set out in § 27(38) UStG (as of 20 October 2026):

PeriodIssuing (invoices to businesses in Germany)Receiving
supplies until 31 Dec 2026paper or, with the recipient’s consent, PDF, if transmitted by 31 Dec 2026mandatory since 1 Jan 2025
supplies from 1 Jan 2027e-invoice mandatory if total turnover in 2026 was above €800,000; otherwise paper or, with the recipient’s consent, PDF allowed until 31 Dec 2027mandatory
supplies from 1 Jan 2028e-invoice mandatory for everyone (exemptions below)mandatory
EDI proceduresstill allowed until 31 Dec 2027

Two dates count: when you carry out the supply and when you transmit the invoice. For supplies made in 2026, § 27(38) no. 1 UStG only allows paper or PDF if the invoice is transmitted “by 31 December 2026” (bis zum 31. Dezember 2026). So where possible, invoice work done in December 2026 by 31 December 2026, or issue it as an e-invoice straight away. If you want to invoice such work only in January 2027, clarify this with your tax adviser first. That a January dispatch is then no longer covered is our reading of the statute, not a statement by the BMF.

There is no exemption for receiving: small businesses under the small-business scheme must accept e-invoices too. According to the BMF (Federal Ministry of Finance), an ordinary email inbox is enough for this.

E-invoicing mandate 2027: the law and what is still open

No law has postponed the timeline so far. The government draft of the Annual Tax Act 2026 (Jahressteuergesetz 2026, Bundestag printed paper 21/8283 of 30 September 2026) does not change § 27(38) UStG. The act has not been passed yet, though, and we could not see any amendments from the Bundestag finance committee. “No postponement” is therefore a finding as of 20 October 2026, not a promise. Check the status again before the turn of the year, before you rely on it.

The German Confederation of Skilled Crafts (ZDH) asks, in its paper “ZDH kompakt” of 17 June 2026, for the 1 January 2027 date to be moved to 1 January 2028. Among its reasons: the revised EN 16931 standard for B2B and the matching mapping are still missing. That is the position of an industry association, not law in force. We found no response from the federal government. So plan for 1 January 2027.

What applies to trades and mid-sized businesses

The mandate applies to supplies to other businesses when both sides are resident in Germany (§ 14(2) sentence 2 no. 1 UStG). Invoices to private customers are not covered, and according to the BMF neither are many tax-exempt supplies under § 4 nos. 8 to 29 UStG. Under the UStG and the UStDV (VAT implementing ordinance), you also need no e-invoice, among other cases, for small amounts up to €250 gross (§ 33 UStDV), for travel tickets (§ 34 UStDV), as a small business under the small-business scheme (§ 34a UStDV), and for supplies to legal entities that are not businesses. Public-sector clients have their own requirements, such as the federal E-Invoicing Ordinance (E-Rechnungsverordnung) (BMF letter of 15 October 2026, Rn. 24 to 25); there, the stricter rule applies.

What the BMF letter of 15 October 2026 clarifies

On 15 October 2026 the BMF published a supplementary letter (reference GZ III C 5 - S 7287-a/00019/021/017). For businesses with jobs running across the turn of the year, these points matter most (as of 20 October 2026; Rn. = margin number):

The BMF intends to review the rules “in due course” (zu gegebener Zeit) with regard to the reporting system (Meldesystem).

Formats: XRechnung and ZUGFeRD

According to the BMF, “in particular the formats XRechnung and ZUGFeRD customary in Germany, from version 2.0.1 (with the exception of the MINIMUM and BASIC-WL profiles)” meet the VAT requirements. The list is not exhaustive: other formats under the EN 16931 standard, or a format agreed between the contracting parties such as an EDI procedure, are also possible if the required details can be extracted from it correctly and completely. If an invoice has an image part and a structured part, the structured part counts: “If the structured part of the invoice differs from the image part, the data of the structured part are now authoritative.” So check the data, not just the PDF image. (As of 20 October 2026)

Many invoicing and trade software products already create e-invoices. According to the vendors, as of 20 October 2026, this applies for example to pds (ZUGFeRD and XRechnung, receiving and sending without add-on modules), HERO (creates ZUGFeRD and XRechnung), Lexware Office (creating and sending) and sevdesk (ZUGFeRD, creating in all plans, receiving from the “Buchhaltung” plan). The order is not a ranking. Ask your vendor which format and which profile your version produces.

Retention: eight years, structured part

You keep invoices for eight years (§ 14b(1) sentence 1 UStG). For an e-invoice, according to the BMF, “at least its structured part” must stay intact. Under the GoBD (German principles for proper electronic bookkeeping; BMF letter of 14 July 2025, Rn. 119), you only need to keep the PDF part if it contains “additional or differing information” relevant for taxation, for example booking notes. If you store e-invoices outside a GoBD-compliant system: for VAT purposes (§ 14b UStG), according to the BMF, this is as a rule not a breach; the GoBD requirements under the Fiscal Code (Abgabenordnung) still apply.

Under § 147(3) sentence 1 AO (German Fiscal Code), booking vouchers must be kept for eight years, books and annual financial statements for ten years and other documents for six years, each in the version applicable since 1 January 2025. Copies of your quotes, as business letters, are probably subject to the six years. That is our assessment, not a statement by the tax authorities; clarify it with your tax adviser. (As of 20 October 2026)

Automating quotes: what AI can and cannot do

In our reading of § 14(1) sentence 1 UStG, a quote is not an invoice, because it does not yet bill a supply. The e-invoicing mandate therefore does not apply to it. We are not aware of an explicit statement by the BMF on this. (As of 20 October 2026)

Quotes still involve a lot of office work, and this is where AI can help. From an enquiry, a site measurement (Aufmaß), a bill of quantities and your price list, it can prepare a draft quote: assign line items, carry over quantities, flag missing details. A person reviews the draft. That person sets binding prices, discounts, payment terms and legal wording, not the AI.

We cannot put a credible number on how much time this saves per quote. We found no reliable measurement that does not come from a vendor. Anyone who quotes you a fixed number of minutes should say where it comes from.

Automating invoices: outgoing and incoming

For outgoing invoices, the invoice is created from the order in your invoicing or trade software. An automation can check beforehand whether all line items from the order and the site measurement are included, and afterwards whether the generated file matches the format. For overdue items it can prepare a draft payment reminder that only goes out after your approval.

In our assessment, the bigger lever is on the incoming side. Capturing incoming invoices, matching them against purchase order and job, and flagging discrepancies is routine work that comes up with every supplier. The best figure we found comes from an IW Consult study of 4 November 2025 for the “Partnerschaft für Finanzdigitalisierung” (Partnership for Finance Digitalisation). In a telephone survey of 201 SMEs in April and May 2025, the businesses stated their average processing time per incoming invoice as 9 minutes for a paper invoice, 7 minutes for a digital invoice and 6 minutes for an e-invoice (responses per value: 79 to 152). These are self-reported figures, not measurements, and they only concern incoming invoices.

When it is not worth it: if your software already produces and receives e-invoices and you have few invoices a month, a software update and a fixed office routine are often enough. You do not need AI for that.

AI in accounting: what an agent may do

An AI agent in an SME’s accounting should prepare, not decide. It makes no tax decisions, such as whether a supply is tax-exempt or which type of invoice is required. It books nothing without approval. And every step is logged, so that you and your tax adviser can trace what the agent proposed and who approved it.

What an automation can take on here

meine-bots builds AI agents for quote preparation and for invoicing and payment-reminder runs. The AI prepares drafts and checks; the invoice is created in your existing invoicing or trade software. Nothing is sent without approval by a person.

Checklist: what to clarify by 31 December 2026

  1. Is your total turnover in 2026 above €800,000? Estimate this with your tax adviser.
  2. Does your software produce XRechnung or ZUGFeRD from version 2.0.1, and not in the MINIMUM or BASIC-WL profile?
  3. Which inbox do incoming invoices arrive in, and who handles them?
  4. Does your archive keep the structured part unaltered for eight years?
  5. Which jobs run across the turn of the year? Plan progress and final invoices according to Rn. 2 to 4 of the BMF letter of 15 October 2026. Clarify with your tax adviser when you will invoice work done in December 2026.
  6. Can your software send the bill of quantities as an embedded annex and clearly refer to it in the structured part? Test both on a real invoice.
  7. Which of your business customers are businesses in Germany, and how do they want to receive e-invoices?
  8. Has anything changed in the Annual Tax Act 2026 or in § 27(38) UStG? Check shortly before 31 December 2026.

If you want to see where most of the time in your office goes, book the free initial call (30 minutes, first assessment). The next step after that is the AI Check, which is paid and credited towards a follow-up project.

This article is general guidance (as of 20 October 2026) for businesses in Germany and is not legal or tax advice. Please check your individual case with your tax adviser.

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