FlexCode Systems
On 1 January 2027, the grace period for e-invoicing ends for many companies in Germany. If your total turnover in 2026 exceeds 800,000 euros, invoices to other domestic businesses must, as a rule, be issued as structured e-invoices from that date. The PDF invoice by email, still tolerated since 2025, will no longer be enough.
You have had to be able to receive e-invoices since 1 January 2025. Sending them is the bigger step, because it touches every outgoing invoice, every credit note and every place in the company where invoices are still created today. There are a little over three months left until the turn of the year, and for most companies the year-end close sits in between.
This article summarises what applies from 2027, who is affected, which exceptions exist and how to implement the issuing obligation with Odoo. It is a practical overview, not tax advice. Check individual cases, especially around the turnover threshold, with your tax advisor.
The legal basis is the Growth Opportunities Act (Wachstumschancengesetz) of March 2024. It rewrote § 14 of the German VAT Act: for supplies between two businesses established in Germany, the invoice must be issued as an electronic invoice. Under the law, an e-invoice is an invoice that is issued, transmitted and received in a structured electronic format and allows electronic processing.
To avoid an overnight switch, § 27 (38) of the VAT Act sets three transition stages:
From 1 January 2028, these reliefs end. The issuing obligation then applies to all businesses that do not fall under one of the exceptions.
The threshold sounds simple, but it has three details that are often misunderstood in practice.
It is the total turnover under § 19 (2) of the VAT Act. This is not automatically the revenue in your income statement. It means the sum of taxable supplies, calculated on a cash received basis, minus certain VAT-exempt supplies. Sales of fixed assets, such as a used machine, are excluded. And it is your entire turnover, not just the share you make with business customers.
It is the previous year. Whether you may still send PDF invoices in 2027 depends on your total turnover in 2026. If you are close to the threshold, you may only know for sure after the turn of the year. In that case, plan as if you are affected.
It is the date of supply, not the invoice date. The transition rules are tied to when you delivered or performed the service. Watch out for December 2026 supplies that you only invoice in January 2027: according to the wording of the law, the relief for 2026 supplies only covers invoices transmitted by 31 December 2026. Issue those invoices in time or directly as e-invoices, and clarify open cases with your tax advisor.
If your company is part of a VAT group (Organschaft), agree explicitly with your tax advisor how the threshold applies.
Not every invoice has to be an e-invoice. The main exceptions are:
Note that the exception always applies to the individual invoice. A company with a mixed customer base therefore needs clear rules on which format is produced when.
The format must comply with the European standard EN 16931 or be convertible into such a format without loss. In Germany, that means two formats in practice:
A PDF that merely looks good is not an e-invoice, even if it arrives by email. In its second circular on e-invoicing, dated 15 October 2025, the Federal Ministry of Finance also clarified:
For your customers, this is not a formality. A PDF invoice where an e-invoice is mandatory is not a proper invoice. The customer risks their input VAT deduction and will request a correct e-invoice. At that point, the issue lands on your desk.
Technology is rarely the problem. These are the hard parts:
The good news: Odoo includes e-invoicing as standard, with no paid add-on module.
Odoo 19 creates an XRechnung or a ZUGFeRD invoice from every customer invoice (Odoo calls it Factur-X, which is technically the same format). You set which format each customer receives on the contact, in the Accounting tab, using the e-invoice format field. When you send the invoice with the Send button, Odoo attaches the right file automatically.
Your company can also register on the Peppol network in Odoo for free. Germany is one of the supported countries. Invoices then go straight to the customer's Peppol access point, without email in between.
The same technology handles incoming e-invoices. Odoo reads XRechnung and ZUGFeRD, whether by email alias, upload or Peppol, and pre-fills vendor, amounts and taxes. If you only set this up provisionally in 2025, now is a good time to do it properly. Our guide to XRechnung and ZUGFeRD in Odoo walks through the setup step by step.
With the German localisation, Odoo's audit trail is active by default, and changes to posted documents are logged. The e-invoice stays attached to the invoice. Our article on GoBD-compliant accounting with Odoo explains how to set up Odoo for tax audits overall.
For your tax advisor, Odoo exports entries and documents in DATEV format. One detail that is often missed: customer invoices only appear in the DATEV document export if they were generated with the Send button. More on this in our article on the DATEV interface in Odoo.
Odoo produces correct formats when the data is right. In projects, we typically set up the rest like this:
When do I have to issue e-invoices?
If your total turnover in 2026 exceeded 800,000 euros, the obligation applies to supplies from 1 January 2027. If it was lower, you may still use paper or PDF for supplies in 2027 with the recipient's consent. From 1 January 2028, the obligation applies to all businesses that do not fall under an exception.
Does the 800,000 euro threshold refer to my total turnover or only the B2B share?
What counts is the total turnover under § 19 (2) of the VAT Act in the previous year, meaning taxable supplies on a cash received basis minus certain exempt supplies. It is not limited to business with corporate customers. Sales of fixed assets are excluded.
Do small businesses have to issue e-invoices?
No. Under § 34a UStDV, small businesses (Kleinunternehmer) may permanently send their invoices as other invoices, on paper or as PDF. They may issue e-invoices voluntarily. Like every other business, they must still be able to receive e-invoices.
Is a PDF with embedded XML an e-invoice?
Yes, if the XML complies with an accepted format such as ZUGFeRD from version 2.0.1 and does not use the MINIMUM or BASIC-WL profile. The XML part is then authoritative. A normal PDF without structured data is not an e-invoice.
What happens if I still send a PDF invoice in 2027?
Where an e-invoice is mandatory, a PDF invoice is not a proper invoice. Your customer risks their input VAT deduction and will request a correct e-invoice. That costs time, delays payment and strains the customer relationship.
Can Odoo issue e-invoices without an add-on module?
Yes. Odoo 19 creates XRechnung and ZUGFeRD as standard and can also send invoices via Peppol. What makes invoices error-free is clean master data, the right format per customer and testing before go-live.
The issuing obligation is not an IT task to finish in the last week of December. It touches master data, invoice sources, customer coordination and the archive. Companies that start now go into the new year with tested processes instead of rejected invoices.
FlexCode sets up e-invoicing in Odoo, from master data cleanup and formats to Peppol, validation and the DATEV handover. Request a demo or talk to us about your invoicing processes, or email info@flexcodesys.com. One System. Total Control.