E-Invoicing Obligation: Why 54% of SMEs are Unprepared in 2026

E-Invoicing Obligation: The Current State of Affairs in Companies

An April 2026 survey shows that 54 percent of the small and medium-sized enterprises surveyed are not yet prepared for the e-invoicing obligation. Specifically, in a survey by the portal der-business-tipp.de among 97 companies, around 28 percent stated that they had taken no measures at all so far. Even though this specific sample is small and not representative, the fundamental trend is supported by large-scale studies. For example, an international study by Sage among more than 9,000 SMEs and 2,250 accountants and tax advisors shows that a quarter of the businesses do not feel adequately equipped. The pressure to act is real, as the legal requirements from the Growth Opportunities Act are already in effect and the grace periods for active sending are ending soon.

Which Deadlines and Revenue Limits Now Set the Pace

Since January 1, 2025, every domestic B2B company must be able to receive electronic invoices, while the sending obligation takes effect in stages starting in 2027. This receiving obligation applies without exception and regardless of the size, legal form, or revenue of the company. The next major turning point follows on January 1, 2027. From this date, all companies whose total taxable revenue in 2026 exceeded the limit of 800,000 euros must mandatorily send domestic B2B invoices as e-invoices. The decisive factor for this threshold is the total revenue within the meaning of Section 19 (2) of the Value Added Tax Act (UStG). This means the total taxable revenue of the entire company in the previous year counts, not just the profit or isolated revenue from B2B transactions. Forecasts also play no role; the actual financial statement of the year 2026 is decisive. Exceeding the limit during the year 2027 also has no retroactive effect on this baseline.

Those who remain below the 800,000 euro limit are by no means exempt from the obligation to send, but merely gain one year of time. From January 1, 2028, the sending obligation applies to all remaining B2B companies. Only entrepreneurs who fall under the small business regulation according to Section 19 (1) UStG, as well as invoices for small amounts up to 250 euros and travel tickets, remain permanently exempt from the issuing obligation. Important here: The obligation to receive electronic invoices remains in place for these groups as well. For companies that already use EDI procedures, there is a transitional arrangement: From 2027, these may continue to be used provided they are interoperable with the EN 16931 standard.

Why the Simple PDF Document is Obsolete

A pure PDF invoice via email no longer meets the legal requirements, as structured data according to the EN 16931 standard is mandatory. The Federal Ministry of Finance (BMF) has unequivocally clarified that in the future, only those documents will be recognized as e-invoices that are issued, transmitted, and received in a structured electronic format that enables automated electronic processing. A simple PDF document, which merely transports the visual image of an invoice, does not achieve this. In Germany, the formats XRechnung and ZUGFeRD from version 2.0.1 have primarily established themselves for implementation.

The legal framework conditions are continuously being specified. In a second BMF letter dated October 15, 2025, a clear separation between pure format errors and content-related business rule errors was introduced for the first time. In addition, the ministry clarified that credit notes within the meaning of Section 17 UStG will also fall under the requirements in the future, provided they are de facto issued as an invoice. Companies must therefore adjust their systems not only for sending but also for the correct content validation of these structured data sets.

How Retention Periods and GoBD Requirements Have Changed

Through the Fourth Bureaucracy Relief Act (BEG IV), the retention period for accounting documents has been retroactively shortened from ten to eight years. This new regulation according to Section 147 (3) of the Fiscal Code (AO) and Section 257 (4) of the Commercial Code (HGB) applies to all documents whose original retention period had not yet expired on January 1, 2025. Although the outdated ten-year period still circulates on many older advice sites, e-invoices only need to be archived for eight years according to current law. However, the basic GoBD requirements for archiving remain strictly unchanged. A solution must mandatorily fulfill six criteria: completeness, immutability, traceability, access protection, security, and availability during the entire retention period.

When storing e-invoices according to Section 14 (1) sentences 3 and 6 UStG, such as the hybrid ZUGFeRD format, storing the structured XML part is generally sufficient. A significant relief was also brought by the second GoBD update of July 14, 2025: Companies using an invoicing system will no longer have to archive an additional copy in the form of a PDF or on paper in the future. Double archiving for outgoing invoices is eliminated, which significantly streamlines digital processes.

How a Document and Accounting System Automates Implementation

A modern document and accounting system converts incoming receipts into finished booking proposals without media discontinuity and ensures GoBD compliance up to payment. To bridge the gap between the already applicable receiving obligation and the upcoming sending obligation, a pure document archive is not enough. The technology must directly utilize the structured data of the e-invoices and simultaneously process unstructured legacy formats. The system reads receipts via OCR and AI vision, which works even with handwritten notes, and creates a finished booking proposal from them, including accounts, splits, and tax keys.

The decisive difference to older systems lies in the ability to learn instead of rigid rules. Every booking confirmed or corrected by a human trains the system, whereby the quality of the proposals per creditor increases measurably. An orchestrator relies on four sources: firmly defined rules, the booking history, machine learning, and large language models. This orchestrator decides in a three-stage safety net whether a receipt is processed automatically, presented for human review, or must be booked completely manually. Nothing is waved through blindly; control remains within the company.

At the same time, the archive transforms from a pure storage facility into an information-capable database. Users no longer have to search for file names or folder structures but can ask the archive questions in natural language. A query like "How high were the additional claims from the pension insurance from 2024 — and where are the notices?" is answered in seconds, including a direct source link to each relevant notice. In this way, the legal obligation is used for process optimization that goes far beyond the mere storage of XML files.