2026 BUSINESS LAW UPDATE
Published 13 November 2026 · Developments reviewed for this update.
Germany’s general transition allowing other invoice formats for relevant domestic B2B transactions runs until 31 December 2026. The Finance Ministry’s March 2026 guidance distinguishes structured e-invoices from ordinary PDF invoices and explains exceptions and extended transitions.
What it means for businesses
The Ministry identifies a further transition through 2027 for issuers whose previous-year turnover does not exceed €800,000, and a separate EDI provision. Receiving structured e-invoices has already been relevant since 2025. Businesses should verify their situation rather than assuming every invoice must change on the same date.
Check the invoice process from issue to archive
The transition assessment should distinguish the ability to receive an invoice from the rules for issuing it and from the applicable exceptions. Map the entities, transaction types, systems and counterparties involved. A visually readable PDF and a structured invoice are not interchangeable simply because both arrive by email. Finance and IT teams should agree which formats are supported, how data is validated and how original records are retained.
Implementation and documentation
Review invoicing clauses, purchase-to-pay workflows and the handling of rejected or corrected invoices. The operational plan should address suppliers using different systems and avoid duplicate posting when several representations of one invoice are received. Test realistic transactions, including credit notes and corrections, before changing the production process. The tax assessment should confirm the applicable transition for the business rather than relying on a general statement that every company has the same deadline.
Four practical examples
Illustrative scenarios, not reports of client mandates.
Larger supplier
A supplier tests structured invoice generation before its applicable transition ends.
Practical approach. The supplier should confirm its own transaction and transition position and test the required output. The customer’s preferred format should also be reflected in the agreed communication process.
PDF workflow
An accounts team recognises that an ordinary PDF is not a structured e-invoice.
Practical approach. The receiving process needs responsibility for validation, exceptions and retention. A technical inbox is not enough if staff cannot identify or resolve an invalid invoice.
Small issuer
A business checks eligibility for the turnover-based extended transition.
Practical approach. Record the basis for relying on a transition or exception and set a review date. System changes should be planned early enough that legal readiness and technical readiness coincide.
Public customer
A supplier distinguishes tax rules from separate requirements for invoicing public authorities.
Practical approach. Public-sector invoicing requirements should be checked separately for the relevant customer and channel. The general business-to-business transition does not by itself answer which format or reference the public purchaser requires.
Next steps
Identify the affected group companies, products and contracts. Allocate responsibility for legal assessment and supporting documentation. Check the applicable provisions and transition rules before changing operational processes or giving commitments to counterparties.
Official source and further details
Discuss your business matter
Tell us which parties and countries are involved, what you want to achieve and whether a deadline is approaching. We will clarify the scope, the appropriate legal team and the fee arrangements before work begins.