On 1 January 2027, the grace period for e-invoicing ends for many businesses in Germany. Any business with more than €800,000 in turnover in 2026 must then, as a rule, issue invoices to other German businesses as structured e-invoices. A busy restaurant, hotel or caterer reaches that threshold quickly.
This post sets out what the rule says, where hospitality is affected and what to do in the next eight weeks. It is based on the German VAT Act and the Federal Ministry of Finance FAQ (German, updated October 2026).
The three stages
- Since 1 January 2025: receiving. Every business established in Germany must be able to receive e-invoices. The ministry allows no exceptions, not even for small businesses. An email inbox is enough.
- From 1 January 2027: sending, above €800,000. The transition rule in section 27(38) of the VAT Act allows paper and PDF invoices in 2027 only if the issuer's total turnover in the previous year was not more than €800,000. For 2027, your 2026 turnover is what counts.
- From 1 January 2028: sending, for everyone. The obligation then applies to every issuer of domestic business-to-business invoices, regardless of size.
Trade associations have called for the 2027 stage to be pushed back a year (ZDH, German). That has not happened: the ministry's FAQ of 29 October 2026 still gives the same dates.
What counts as an e-invoice
An e-invoice is an invoice in a structured format that software can process (section 14 of the VAT Act). A PDF sent by email is not an e-invoice. According to the ministry, XRechnung and ZUGFeRD from version 2.0.1 qualify, except the ZUGFeRD profiles MINIMUM and BASIC-WL. In hybrid formats such as ZUGFeRD, the XML data now takes precedence over the visible PDF.
What it means for restaurants and hotels
The rule only covers invoices to other businesses in Germany. A private guest still gets a till receipt. Three cases need attention:
1. Business meals over €250. The ministry uses the business lunch in a restaurant as an explicit example: even when paid in cash, an e-invoice is due when the amount is over €250 and no transition rule applies. It suggests handing over a till receipt on the spot, asking for the guest's email address and sending the e-invoice afterwards.
2. Catering, events and company parties. These invoices almost always go to businesses and are usually well over €250. Your invoicing software should be able to produce e-invoices from January.
3. Hotel bills for business travellers. Rooms billed to a company are business-to-business sales. Above €250, they need an e-invoice from 2027 if your previous year's turnover is over the threshold.
Invoices up to and including €250 gross (section 33 of the VAT Implementing Ordinance) may still be issued on paper or as a PDF. That covers a large share of restaurant bills.
The other side: your supplier invoices
Incoming invoices matter just as much. Wholesalers, drinks suppliers and laundry services are almost all above €800,000 in turnover, so from January their invoices will increasingly arrive as XRechnung or ZUGFeRD, while smaller suppliers may keep sending paper and PDFs until the end of 2027.
For the next two years you will handle three formats at once: paper, PDF and e-invoice. Running three filing systems and three approval routes for them costs exactly the time e-invoicing is supposed to save.
Your checklist before 31 December
- Check your 2026 turnover. Is total turnover, as defined for VAT, above €800,000? Confirm it with your tax adviser rather than reading it off a management report.
- Ask your till and invoicing software providers whether they can issue XRechnung or ZUGFeRD, including after the fact for a till receipt.
- Set one email address for invoices that someone works through daily, and give it to every supplier.
- Sort out approval and archiving. E-invoices must be kept in their original format. A printed PDF is not enough.
How Bazaro helps
InvoiceIQ brings your supplier invoices into one flow, whether they arrive by email, by upload or through a direct supplier connection. The AI in docVision captures line items, amounts and VAT rates with 99.8% field accuracy, with data processed in the EU. Invoices then go through your approval flow, with one-click approval by email if you want it, and on to your accounting.
Whether your suppliers send e-invoices or PDFs in 2027, talk to us about how your invoice intake should work.
This post is not tax advice. Information as of 31 October 2026.