From 1 January 2027, if your German entity had more than EUR 800,000 in total revenue in 2026, every invoice it sends to another business in Germany must be a structured e-invoice in a format such as XRechnung or ZUGFeRD. From 2028 the rule covers every German business. A PDF attached to an email no longer counts. Because a new ERP cannot realistically go live in the 80 days left, the 2027 deadline has to be met in the system you run today, while the 2028 deadline and every ERP selection under way need e-invoicing as a hard requirement.
This guide is for finance and IT leads at companies with a German subsidiary, a German branch, or a German customer base invoiced from a German entity. It reads the rules directly from the German VAT Act (UStG) as published on 13 October 2026, sets out what an ERP has to do technically, measures how long implementation takes across the 19 active systems we compare, and checks which vendors document native support. It is not tax advice for your specific case.
What changes on 1 January 2027?
The general transition period for issuing invoices ends. Since 1 January 2025, an invoice from one domestic business to another has in principle had to be an e-invoice (section 14(2) UStG). The transitional rule in section 27(38) UStG still lets every business send paper or, with the recipient's consent, other electronic formats such as PDF until 31 December 2026. For supplies made in 2027, that relief only remains for businesses whose total revenue in the previous year did not exceed EUR 800,000.
| Date | What changes |
|---|---|
| 1 Jan 2025 | E-invoice becomes the default. Receipt required, consent no longer needed |
| 31 Dec 2026 | General transition ends. Paper and PDF only for supplies up to 2026 |
| 1 Jan 2027 | Issuing mandate above EUR 800,000. Based on total revenue in 2026 |
| 31 Dec 2027 | Relief ends for small issuers and EDI. Up to EUR 800,000 revenue, or EDI |
| 1 Jan 2028 | Issuing mandate for everyone. No transition rule left for domestic B2B |
Sources: section 14 UStG and section 27(38) UStG, statutory text on gesetze-im-internet.de, retrieved 13 October 2026.
There is no transition period for receiving. Under section 14(1) UStG, sending an e-invoice needs no consent from the recipient where the mandate applies. Every German business therefore has to accept and process e-invoices since 2025, even if it still sends paper itself.
Does the mandate apply to your company?
It applies when both the supplier and the business customer are established in Germany. "Established" includes a registered office, place of management, or a permanent establishment involved in the supply (section 14(2) UStG). A US or UK parent invoicing a German customer from abroad is outside the domestic rule; its German subsidiary invoicing the same customer is inside it.
- Threshold. The EUR 800,000 test uses the issuing entity's total revenue in the previous calendar year, not its B2B revenue and not group revenue.
- Small invoices. Invoices up to EUR 250 may always be sent in other formats (section 33 UStDV).
- EDI. Businesses already exchanging invoices by EDI under EU Recommendation 94/820/EC may continue, with the recipient's consent, until the end of 2027 regardless of revenue (section 27(38) no. 3 UStG).
- Out of scope. Invoices to consumers, invoices to customers abroad, and VAT-exempt supplies under section 4 nos. 8 to 29 UStG.
Group structures need an entity-by-entity check
The threshold is tested per issuing company, so a group can have German entities on both sides of the line. A small German sales subsidiary may still send PDFs in 2027 while the German manufacturing entity of the same group may not. Map each German legal entity before you scope the project.
Which formats count as an e-invoice in Germany?
Under section 14(1) UStG, an e-invoice is issued, transmitted and received in a structured electronic format that complies with the European standard EN 16931, or a format agreed between the parties that can be converted into one without loss. Two formats dominate in Germany:
- XRechnung: pure XML following the German specification maintained by KoSIT, the government coordination office for IT standards. It has been required for public-sector invoicing for years.
- ZUGFeRD (the same standard as France's Factur-X): a PDF/A-3 with embedded XML. According to the FAQ of FeRD, the German e-invoicing forum, ZUGFeRD from version 2.0.1 qualifies, except the MINIMUM and BASIC WL profiles. EN 16931, EXTENDED and the XRECHNUNG profile are valid. The current release is ZUGFeRD 2.5.2, published on 4 August 2026.
FeRD is explicit that in a ZUGFeRD file the embedded XML is the invoice, not the PDF. For an ERP that means invoice data must come out of billing complete and structured. Scraping a PDF after the fact does not produce a compliant invoice.
What does your ERP have to do?
Five things, not one. Many requirement documents only say "XRechnung export". That covers sending and leaves the rest of the obligation open.
- Create. XRechnung and ZUGFeRD with a valid profile straight from billing, including credit notes and corrections, in a current format version.
- Validate. Check against the business rules before sending, so missing mandatory fields such as the buyer reference are caught internally.
- Send. By email, a customer portal, or the Peppol network, depending on what your German customers accept.
- Receive and process. Read incoming XRechnung and ZUGFeRD files, match them to purchase orders and receipts, and post them. This has been mandatory since 2025.
- Archive. Keep invoices for eight years (section 14b(1) UStG) in their original format, which for an e-invoice is the XML file, under the German bookkeeping rules known as GoBD.
💡 Key Takeaway
Do not test an ERP for "supports XRechnung". Test all five steps: create, validate, send, receive, archive. The gaps are usually on the inbound side and in archiving the XML.
Can a new ERP go live before the deadline?
Almost never. There are 80 days between 13 October 2026 and 1 January 2027. We took the lower bound of the typical implementation time from our product data for all 19 active systems we compare, meaning the fastest realistic case. For only 4 of 19 is it shorter than 80 days, and only for small projects running standard processes.
| Lower bound of typical implementation time | |
|---|---|
| Time left until 1 January 2027 | 80 days |
| Odoo (simple rollout) | from 4 weeks |
| Dynamics 365 Business Central | from 8 weeks |
| SAP Business One | from 2 months |
| Sage Intacct | from 2 months |
| SAP S/4HANA Cloud Public Edition | from 3 months |
| Oracle NetSuite | from 3 months |
| Acumatica | from 3 months |
| SYSPRO | from 3 months |
| Epicor Kinetic | from 4 months |
| proALPHA | from 4 months |
| Unit4 ERP | from 4 months |
| Dynamics 365 Finance & SCM | from 6 months |
| IFS Cloud | from 6 months |
| Sage X3 | from 6 months |
| QAD Adaptive ERP | from 6 months |
| SAP S/4HANA Private Edition | from 8 months |
| Oracle Fusion Cloud ERP | from 8 months |
| Infor CloudSuite | from 9 months |
| SAP S/4HANA On-Premise | from 12 months |
Source: ERP Pilot product data (typical implementation time per system, lower bound of the stated range), 19 active systems of the ERP Pilot comparison excluding the withdrawn SAP Business ByDesign, read on 13 October 2026. The upper bound falls after the deadline for every system.
Even the four fastest cases assume a contract signed today and no complex data migration. For a German entity above the threshold, the 2027 obligation will be met with today's ERP, an add-on, or a service provider. The selection of the next ERP is where you make sure the workaround is not needed again.
When do ERP buyers plan to go live?
Mostly well after the deadline. Between 14 February and 12 October 2026, 244 people told the ERP Pilot quiz when their new ERP needs to be live. 190 of them (78%) planned more than six months out or had no fixed date. Even the 54 on the tightest plan would land in spring 2027 if they started in October 2026.
| Share of all runs that answered the timeline question | |
|---|---|
| Within 6 months | 54 runs, 22% |
| 6 to 12 months | 97 runs, 40% |
| 12 to 24 months | 60 runs, 25% |
| No fixed date | 33 runs, 14% |
Source: ERP Pilot quiz data, 14 Feb to 12 Oct 2026, English and German versions combined, n = 244 runs that answered the timeline question. "No fixed date" includes 4 answers to an earlier option without a date. Self-selected sample of people evaluating ERP, not a market survey. Measured 13 October 2026.
The sample is global, not German, and the point does not depend on that: implementation takes no less time in Germany, and nobody who answers "six months or more" will be live on 1 January 2027. Selection projects that touch a German entity therefore carry two separate tasks that are easy to blur: a bridge for 2027, and a requirement for the new system.
Which ERP systems support German e-invoicing out of the box?
Fewer than the marketing pages suggest. On 13 October 2026 we looked for each vendor's own documentation, not partner blogs. Only the two Microsoft systems document both creating and receiving German e-invoices as standard. Odoo documents both formats for sending. For most other systems we found no publicly accessible vendor source that names XRechnung or ZUGFeRD specifically.
| System | Create e-invoices | Receive e-invoices |
|---|---|---|
| Dynamics 365 Business Central | Yes, standard: XRechnung (UBL), ZUGFeRD, Peppol BIS 3 (Microsoft Learn) | Yes, standard (E-Documents) |
| Dynamics 365 Finance & SCM | Yes, standard: XRechnung; ZUGFeRD not mentioned (Microsoft Learn) | Yes, XRechnung (Microsoft Learn) |
| Odoo | Yes, standard: XRechnung (UBL) and Factur-X/ZUGFeRD (CII) (Odoo documentation) | Not documented |
| SAP S/4HANA Cloud Public Edition | Through the SAP Document and Reporting Compliance service (SAP knowledge base); scope not checked | As for sending; scope not checked |
| Infor CloudSuite (M3) | Through Infor Localization Services Platform, XRechnung 1.2.2 (Infor documentation for M3 BE 15.1.4) | Not documented |
| Oracle NetSuite | Not documented | XRechnung through the EU Electronic Invoicing SuiteApp (NetSuite help) |
| SAP Business One | Not documented | ZUGFeRD import as document draft, German localization (SAP guide) |
| proALPHA | Not documented | Own module for inbound structured e-invoices (proALPHA, German page) |
| SAP S/4HANA Private Edition, On-Premise | Not documented | Not documented |
| Oracle Fusion Cloud ERP | Not documented | Not documented |
| IFS Cloud | Not documented | Not documented |
| Epicor Kinetic | Not documented | Not documented |
| Sage X3 | Not documented | Not documented |
| QAD Adaptive ERP | Not documented | Not documented |
| Unit4 ERP | Not documented | Not documented |
| Acumatica, Sage Intacct, SYSPRO | No German localization in our data | No German localization in our data |
Sources: vendor documentation, linked in each row, checked 13 October 2026. "Not documented" means we found no publicly accessible vendor source naming XRechnung or ZUGFeRD. It does not mean the system cannot do it: several vendors deliver German e-invoicing through partners, add-on services, or documentation behind a customer login. SAP Business ByDesign is left out because SAP has ended new sales. Acumatica, Sage Intacct and SYSPRO are not part of our German comparison set because they lack a DACH localization.
The practical rule for selection: ask every vendor to demonstrate it, including the documented ones. The Dynamics 365 Finance & SCM documentation names XRechnung but not ZUGFeRD, and the NetSuite and SAP Business One documentation covers receiving, not sending. If a German entity is one of several in your group, a system whose vendor documents German e-invoicing as standard, such as Business Central, carries less project risk on this point than one where e-invoicing comes from a partner add-on that has to be licensed and maintained separately.
Why we do not use partner claims
Implementation partners often advertise their own e-invoicing extension for a system. That can work well, but it is not the vendor's standard and comes with its own licence and its own maintenance. The table therefore shows only what the vendor itself documents.
What if your current ERP cannot produce e-invoices?
For 2027 there are three routes, and none requires a new ERP. Which one fits depends on whether your system still receives vendor updates.
- Vendor update. If your release is still maintained, check whether the vendor ships German e-invoicing through an update or localization. This is the cleanest route because future format versions come with it.
- Add-on or converter. A tool that reads invoice data from the ERP and generates XRechnung or ZUGFeRD. Make sure it receives structured data from the ERP rather than parsing a PDF.
- Service provider. An e-invoicing service handles creation, sending, receipt and archiving. Fast, but one more interface and a recurring cost.
Unmaintained systems are the hard case, because regulatory changes no longer come from the vendor. That applies to older Dynamics NAV releases, covered in our Dynamics NAV upgrade guide, and to SAP ECC after the end of maintenance, covered in SAP ECC end of life. There, the 2027 bridge is also a reason to start the ERP selection now.
What should you ask vendors now?
Six questions separate real e-invoicing capability from an export button:
- Which formats and profiles do you produce as standard? Current XRechnung, ZUGFeRD with the EN 16931 or XRECHNUNG profile. MINIMUM and BASIC WL do not qualify.
- Is it standard, a paid add-on, or a partner product? Ask for the licence line item.
- How are inbound e-invoices processed? Ask about matching to purchase orders and receipts, not just import.
- How and where is the XML archived? Eight years, GoBD-compliant, original format.
- Who maintains new format versions? Both XRechnung and ZUGFeRD are updated regularly; FeRD has already announced the next ZUGFeRD release.
- Do you support Peppol and the portals of your key German customers? The sending channel is decided by your customers.
If you are building a shortlist that includes a German entity, add e-invoicing as a knockout criterion next to local GAAP (HGB) and GoBD. Everything else depends on industry, size and structure. The order of the other decisions is set out in our ERP selection guide, and the cost side in the ERP pricing guide.