E-invoices in the trades: automating invoice intake

Trades businesses in Germany have had to be able to receive e-invoices since 1 January 2025, and a mailbox is enough. They must issue them from 1 January 2027 if their total turnover in the previous year exceeded 800,000 euros, otherwise from 1 January 2028. An e-invoice is an invoice as a structured file that a program can read. A workflow can prepare the intake: it collects the invoices, checks them formally, matches them to a job and files them. Whether the invoice is correct and what applies for tax purposes is decided by people.

What applies since when

The deadlines are in section 27(38) of the VAT Act (UStG). Until 31 December 2026 a supplier may still send paper or, with the recipient’s consent, another electronic format such as a PDF file. That applies only to supplies made in 2025 or 2026, and only to invoices transmitted by the end of 2026. Both conditions must be met together. If the supplier’s total turnover in the previous year was at most 800,000 euros (section 19(2) UStG, based on payments received), the same relief applies to supplies made in 2027, provided the invoice is transmitted by the end of 2027. Consent needs no particular form and can be tacit (Ministry of Finance circular 2024, margin no. 63), for example by accepting the invoice without objection (no. 20).

For you as a recipient this means that a PDF file arriving in January 2027 for work done in December 2026 does not, on the wording, fit the first stage any more. That is my reading; your tax adviser clarifies the individual case.

Date	What applies
since 1.1.2025	Receipt must be ensured, no exception, no transition (no. 62)
until 31.12.2026	Paper and PDF possible, for supplies in 2025 and 2026 and invoices sent by the end of 2026
until 31.12.2027	the same for supplies in 2027, only if prior-year turnover was up to 800,000 euros
from 1.1.2028	Issuing mandatory for all; exceptions: small amounts up to 250 euros, small businesses exempt from VAT

Since June 2026 the ZDH has demanded that the obligation be postponed to 1 January 2028. As of 13 November 2026 that has not been adopted. Section 27(38) UStG stands unchanged in the statute, the Ministry’s FAQ (status 29 October 2026) still gives the existing deadlines, and the government bill for the Annual Tax Act 2026 (Bundestag printed paper 21/8283 of 30 September 2026) does not amend that paragraph. I found no decision by the Bundestag or Bundesrat. A later change is possible.

Small businesses exempt from VAT must also be able to receive e-invoices (Ministry FAQ, question 12). If a supplier sends the wrong format, the Ministry does not challenge the input VAT deduction for that reason alone, provided you could assume the supplier was entitled to use the transitional rule (no. 59). Whether that applies to you is for your tax adviser.

What is different in the trades

Small amounts: under section 33 sentence 4 of the implementing regulation (UStDV), an invoice with a total of at most 250 euros may always arrive as an other invoice, that is paper, photo or PDF. What counts is the invoice total. If a supplier combines several supplies and the sum exceeds 250 euros, the exception no longer applies (Ministry circular 2024, no. 23).

Private customers: the obligation does not apply to invoices to end consumers, nor to works supplies and services connected with land supplied to non-businesses (section 14(2) sentence 2 no. 3 UStG; Ministry circular 2024, nos. 19 and 20).

Construction services: under the Ministry circular of October 2026, progress invoices issued before one’s own deadline need not be e-invoices (no. 2). For the bill of quantities, the structured part currently needs only the trades with their totals, provided a readable embedded attachment contains the breakdown (nos. 13 and 14). A Ministry letter of 23 February 2026 gives 30 June 2030 for this but does not regard it as final. The obligation also applies where the recipient owes the tax (section 13b UStG; circular 2024, no. 17).

The workflow in six steps

A workflow is a fixed sequence of steps started by an event, here the arrival of an email. The basics are explained in What process automation in a small business is.

1. Mailbox One invoice mailbox, attachments are collected
2. Recognise format XML, PDF with XML, PDF without data, photo
3. Check data set Tool reports errors, report is stored
4. Match Rule or AI suggests, office confirms AI prepares
5. Approval Person checks work, total, bank details
6. Filing Data set unaltered, then tax adviser

Text version of the graphic

• 1. Mailbox: One invoice mailbox, attachments are collected
• 2. Recognise format: XML, PDF with XML, PDF without data, photo
• 3. Check data set: Tool reports errors, report is stored
• 4. Match: Rule or AI suggests, office confirms (the AI prepares)
• 5. Approval: Person checks work, total, bank details
• 6. Filing: Data set unaltered, then tax adviser

1. Mailbox: one dedicated invoice mailbox is enough (circular 2024, no. 40). n8n, a tool for workflows, fetches the emails with its Email Trigger (IMAP) node. It downloads attachments only on request, which according to the documentation increases the effort.
2. Recognise the format: a plain XML file is usually an XRechnung. A PDF file can carry an embedded XML (ZUGFeRD) or be just an image, in which case it is an other invoice. Whether n8n extracts an embedded XML from a PDF is not stated in its documentation.
3. Check: the open-source KoSIT validator (Apache-2.0) can, according to its documentation, run as an HTTP service and accepts XML by POST. The workflow sends the data set and stores the report. The service does not belong on the open internet. The Ministry recommends no particular tool, and the ZDH names differing results between tools as a problem. According to the Ministry, validation does not replace your own check for completeness and correctness (circular 2025, no. 35a).
4. Match: for XML, fixed rules such as a reference or job number are enough. For PDFs and scans an AI step can suggest a job, and the office confirms. Why emails and attachments are to be treated as foreign content is explained in Sorting enquiries and the inbox in a trades office.
5. Approval: a person checks the work done, the quantity and the amount. My suggestion, not evidenced: the workflow holds an invoice when the bank details differ from the master data. 4.1 percent of the businesses surveyed reported cases of fraud by manipulation of received e-invoices (self-reported). The pattern is described in A fixed workflow, one AI step, human approval.
6. Filing: the structured part must be kept for eight years so that it exists unaltered in its original form (circular 2025, no. 60). According to the ZDH a printout is not enough. For a hybrid invoice the data set takes precedence over the PDF image (circular 2024, no. 31). Whether your filing is adequate is for your tax adviser.

If a step fails, nobody notices by themselves. For that n8n can start an error workflow with an Error Trigger that sends an email to a named person.

What the ZDH survey shows, and a calculation

From 12 January to 27 February 2026 the ZDH surveyed 1,926 businesses through 52 chambers. In 2025, 56 percent had turnover under and 44 percent over 800,000 euros. On average the businesses received 1,193 incoming invoices in 2025, of which 574 were e-invoices. That is about 99 invoices a month, 48 percent of them as e-invoices (574 of 1,193). 65.7 percent processed e-invoices manually only. 47.4 percent found receipt more laborious than with PDF invoices. These are self-reported figures from an association that demands a postponement. Since 44 percent of the respondents were above 800,000 euros, the figure is probably lower for small businesses (my assumption).

Now an example with invented data and the author’s assumptions, not measured. The volume follows the survey: a business with 15 employees receives 100 invoices a month, 48 of them as e-invoices. Each invoice takes about 20 minutes until approval, as the website assumes for construction companies. The workflow saves 25 to 40 percent of that on e-invoices, and the graphic shows the lower value. For PDF and paper I assume nothing.

todaywith workflow

• 48 e-invoicesAssumption: 25 % less

  today 960 min
  with workflow 720 min

• 52 PDF and paperno saving assumed

  today 1,040 min
  with workflow 1,040 min

• All 100 invoicesExample, invented data

  today 2,000 min
  with workflow 1,760 min

Source: Invented example; volume from the ZDH survey 2026; 20 min and 25 % are the author's assumptions, not measured

Text version of the graphic

• 48 e-invoices: today 960 min, with workflow 720 min (Assumption: 25 % less)
• 52 PDF and paper: today 1,040 min, with workflow 1,040 min (no saving assumed)
• All 100 invoices: today 2,000 min, with workflow 1,760 min (Example, invented data)
• Source: Invented example; volume from the ZDH survey 2026; 20 min and 25 % are the author's assumptions, not measured

• Today: 100 × 20 = 2,000 minutes, or 33 hours 20 minutes
• E-invoices: 48 × 20 = 960 minutes, of which 25 percent is 240 minutes
• With the workflow: 2,000 − 240 = 1,760 minutes. At a 40 percent saving it would be 384 minutes less, so 1,616.
• Difference: 4 hours to 6 hours 24 minutes a month

Set-up, maintenance and tool costs are not included. The ZDH survey gives average introduction costs of 2,976 euros one-off and 798 euros a year, though for businesses that issue e-invoices themselves. Whether a workflow pays off at your volume only your own measurement will show (Measuring time savings instead of promising them; times per invoice: Incoming invoice processing time).

Where a workflow brings nothing

With few invoices a month a viewer is enough, for example the one in the ELSTER portal or the free Quba viewer. Anyone who books by hand anyway needs only a filing system. Questions to ask before starting are in When not to automate.

What you can do now

1. Set up an invoice mailbox and check whether someone can make an XRechnung readable, for example with the ELSTER viewer.
2. For four weeks, count how many invoices arrive as XML, as PDF with a data set, as PDF without a data set and on paper, and how many are under 250 euros.
3. Ask your tax adviser where XML files should be kept unaltered, whether your prior-year turnover exceeds 800,000 euros and how invoices under section 13b UStG are handled.

General information, not legal or tax advice. Your tax adviser clarifies the individual case. Status 13 November 2026.