No Postponement for the 2028 E-Invoicing Obligation

The 2028 Deadline Is Final

Some businesses are betting that the government will extend the transition period for e-invoicing beyond 2028. They believe, or hope, that the deadlines will be pushed back as they have been in other regulatory contexts. This is a dangerous assumption.

All signals from the federal government, the Federal Ministry of Finance (Bundesministerium der Finanzen), and the European Commission indicate that the January 1, 2028 deadline for mandatory e-invoice sending for all B2B businesses will not be postponed.

This article explains why postponement is unlikely, what the consequences of non-compliance are, and why preparing now is the only sensible strategy.

Why the Government Will Not Postpone

The Wachstumschancengesetz Is Law

The e-invoicing mandate was enacted through the Wachstumschancengesetz (Growth Opportunities Act), which passed through the Bundestag and Bundesrat after extensive debate and negotiation. The phased timeline (2025 reception, 2027 sending for large businesses, 2028 for all) was a carefully crafted compromise. Reopening this timeline would require new legislation, which is politically unlikely.

EU Pressure for Harmonization

The European Commission's VAT in the Digital Age (ViDA) initiative is pushing all EU member states toward mandatory e-invoicing and real-time transaction reporting. The domestic timeline actually aligns with the EU's broader vision. Delaying would put the country behind other EU nations like Italy (already mandatory since 2019), France, Spain, and Poland, all of which have their own e-invoicing mandates.

Tax Revenue Protection

A primary motivation for mandatory e-invoicing is closing the VAT gap, the difference between expected and collected VAT revenue. This gap is estimated at billions of euros annually. Structured e-invoices enable better tax monitoring and reduce fraud. The financial incentive for the government to enforce the deadline is enormous.

Sufficient Transition Time

The government provided a three-year transition period from the initial reception mandate (2025) to the full sending obligation (2028). This was explicitly designed to give businesses of all sizes adequate time to prepare. Arguing for more time after a three-year window is a difficult position to defend.

Technology Readiness

Unlike previous digital mandates where technology was a barrier, the e-invoicing infrastructure is already mature. Peppol is operational, XRechnung and ZUGFeRD are well-established, and affordable solutions like Peppol Box exist for businesses of all sizes. There is no technical reason to delay.

The Complete Timeline Recap

• January 1, 2025: All B2B businesses must receive e-invoices (already in effect)
• December 31, 2026: End of transition period for sending PDF/paper invoices (for businesses above 800,000 EUR revenue)
• January 1, 2027: Businesses with revenue above 800,000 EUR must send e-invoices
• December 31, 2027: End of transition period for all remaining businesses
• January 1, 2028: ALL businesses must send and receive e-invoices for domestic B2B transactions

Consequences of Non-Compliance

Financial Penalties

Violations of the e-invoicing mandate can result in fines of up to 5,000 EUR. While the authorities may apply a pragmatic approach initially, repeated non-compliance will attract enforcement action.

VAT Deduction Risks

If you send invoices that do not comply with the e-invoicing requirements, your customers may not be able to claim their input tax deduction (Vorsteuerabzug). This creates friction with your business partners, who may choose to work with compliant suppliers instead.

Tax Audit Problems

During tax audits (Betriebsprufung), auditors will expect e-invoices to be stored in their original structured format. If you have been sending or receiving non-compliant formats, you may face issues with your archiving obligations.

Business Relationship Damage

As more businesses adopt e-invoicing, those that cannot send or receive compliant invoices become difficult trading partners. Large companies and government agencies already require e-invoices, and by 2028, this will be universal.

Why Waiting Is a Bad Strategy

Some businesses plan to wait until the last possible moment to implement e-invoicing. Here is why this approach is risky:

• Rush adoption leads to errors: Implementing a new system under deadline pressure increases the risk of mistakes, misconfigurations, and compliance gaps
• Support bottlenecks: As the deadline approaches, e-invoicing providers will be overwhelmed with new customers. Wait times for setup and support will increase.
• Staff training: Your team needs time to learn the new workflows. Last-minute implementation does not allow for proper training.
• Trading partner coordination: You need to inform your customers and suppliers about your Peppol ID and e-invoicing capabilities. This takes time.
• Missing early benefits: Businesses that adopt e-invoicing early benefit from reduced costs, faster payments, and fewer errors for years before the mandate forces everyone else to catch up.

How to Prepare Now

Step 1: Start Receiving Today

If you have not already, set up your ability to receive e-invoices. This has been mandatory since January 2025. A Peppol Box account gives you instant reception capability.

Step 2: Begin Sending Early

Do not wait for the sending obligation to reach your business. Start sending e-invoices now to gain experience, work out any issues, and benefit from the efficiency gains immediately.

Step 3: Inform Your Network

Share your Peppol ID with customers and suppliers. Add it to your letterhead, email signature, and website. Encourage your trading partners to register on the Peppol network as well.

Step 4: Train Your Team

Make sure your staff understands the new invoicing workflow. With a simple platform like Peppol Box, training takes minimal time, but it is better to do it now than under deadline pressure.

Step 5: Connect Your Accountant

Set up Flexina Sync so your accountant can automatically retrieve your invoices from Peppol Box — free of charge. This ensures a smooth workflow from day one of the full mandate.

The Bottom Line

The 2028 e-invoicing deadline is not going to be postponed. The legal framework is in place, the political will exists, the EU is pushing for it, and the technology is ready. Every business here, regardless of size, should be preparing now.

The sooner you start, the more you benefit. Early adoption means more time to learn, lower costs from automation, and a competitive advantage with partners who value efficient digital processes.