E-Invoicing: Nine Months Until the Mandate Takes Effect – Where SMEs Stand
4 min Read Time
In nine months, the e-invoicing mandate for SMEs becomes enforceable. Starting January 2027, companies with annual revenues exceeding €800,000 must issue structured electronic invoices. According to Bitkom, as of end-2024, fewer than half of all companies could even receive structured e-invoices. Companies that fail to proactively implement the change now risk fines of €5,000 per non-compliant invoice.
The Key Takeaways
- As of January 2027, companies with annual revenue above €800,000 must issue B2B invoices as structured e-invoices (Growth Opportunities Act).
- As of January 2028, the issuance requirement applies to all companies, regardless of revenue.
- Approved formats: XRechnung (XML) or ZUGFeRD 2.0.1+ (hybrid PDF with embedded XML). Both must comply with the EU standard EN 16931.
- According to the European Commission, e-invoicing reduces invoice processing costs by 55-72 percent.
What’s Changing
The Growth Opportunities Act defines the B2B e-invoicing mandate in three stages. Since January 2025, all companies have been required to be able to receive structured e-invoices – a legal obligation, not optional. Starting January 2027, companies with annual revenue exceeding €800,000 must also issue structured e-invoices. From January 2028, the issuance requirement applies universally.
An “e-invoice” under this law is not a PDF attached to an email. It must be a machine-readable XML format compliant with the EU standard EN 16931. In Germany, two formats are approved: XRechnung (pure XML) or ZUGFeRD version 2.0.1 or later (PDF with embedded XML). A PDF invoice sent as an email attachment does not meet the legal requirements.
Where SMEs Stand Today
The reception mandate has been in force for over a year. Yet industry surveys show many companies still haven’t completed the transition. Bitkom’s data from end-2024 revealed that only 45 percent of surveyed companies could receive structured e-invoices in a machine-readable format. The remainder still process PDFs manually – or rely on proprietary formats.
The bottleneck is rarely the software. DATEV, SAP, Lexware, and sevDesk all natively support e-invoicing. The real challenge lies in internal process transformation: Companies that have historically collected incoming invoices as PDFs in their email inbox must redesign their workflows. Those required to issue e-invoices starting in 2027 need a robust interface between their ERP system and the e-invoicing format.
“E-invoicing isn’t an IT project – it’s a process project with an IT component. Companies that only upgrade software without adapting their workflows will face compliance issues in nine months.”
– mybusinessfuture editorial assessment
What to Do Now
Three steps for companies that haven’t yet begun implementation:
First, conduct an inventory: How many B2B invoices does your company issue per month? Which format does your current ERP system use? Can it export XRechnung or ZUGFeRD?
Second, perform a software check: Most mainstream accounting solutions offer e-invoicing modules. DATEV has integrated XRechnung since 2023; SAP covers it via its Document & Reporting Compliance (DRC) module; Lexware, sevDesk, and FastBill provide native support.
Third, run a test phase. Data quality in master data determines whether e-invoices are generated cleanly. Tax identification numbers, bank account details, and item master data must be complete and accurate.
EU Context: ViDA Arrives in 2030
Germany’s e-invoicing mandate forms part of a broader EU initiative. The ViDA Directive (VAT in the Digital Age) was adopted in March 2025 and mandates e-invoicing for all cross-border B2B transactions within the EU starting July 2030. Companies that implement Germany’s requirements correctly today will already be prepared for ViDA. Those who delay will face a double migration later.
Assessment
E-invoicing is one of the few regulatory mandates that deliver tangible long-term cost savings. Per the European Commission, invoice processing costs drop by 55-72 percent. SMEs stand to benefit disproportionately – since manual processing remains most widespread in this segment. But: Nine months is less time than it sounds – especially if your finance department still needs to complete an ERP upgrade.
Frequently Asked Questions
Is a PDF invoice sent by email sufficient?
No. A PDF is not a structured data format under the law. A machine-readable XML compliant with EN 16931 is required – either as XRechnung or as ZUGFeRD version 2.0.1 or later with embedded XML.
What happens if I miss the deadline?
Starting January 2027, fines of up to €5,000 per non-compliant invoice apply. Additionally, non-compliant invoices may not qualify as valid tax documentation – jeopardizing input VAT deduction.
Which software do I need?
Most widely used accounting solutions already support e-invoicing: DATEV (natively since 2023), SAP (via DRC module), Lexware, sevDesk, and FastBill. What matters most isn’t the software itself – but whether master data is maintained rigorously and internal processes have been adapted accordingly.
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