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Germany

No policy module: resolves to DefaultEUPolicy.

Issue: #1232

Status

No restriction yet. The transition for issuing domestic B2B E-Rechnungen ends on 1 January 2027 for larger issuers, and Revel does not handle it yet.

Since 1 January 2025, an invoice for a supply between two businesses established in Germany must be an E-Rechnung: a structured invoice conforming to EN 16931, such as XRechnung or ZUGFeRD from the EN 16931 profile up. Receiving E-Rechnungen has been mandatory since then. For issuing, a transition applies. Both the supply date and the date the invoice is sent count:

  • supplies in 2025 and 2026: paper, or another electronic format (such as a PDF) with the recipient's consent, if the invoice is sent by 31 December 2026;
  • supplies in 2027: the same, if the invoice is sent by 31 December 2027 and the issuer's prior-year total turnover (Gesamtumsatz, §19 Abs. 2 UStG) did not exceed 800,000 EUR. A separate 2027 route for EDI (with consent) covers only electronic formats, never paper, and does not apply to Revel's e-mailed PDFs.

So for issuers above 800,000 EUR, a PDF for a supply made in 2027 is no longer a valid B2B invoice.

Not covered:

  • invoices up to 250 EUR gross (Kleinbetragsrechnungen), except for supplies under §§3c, 6a and 13b UStG (§33 S. 3 UStDV);
  • supplies exempt under §4 Nr. 8 to 29 UStG;
  • invoices for supplies of small businesses under §19 UStG (Kleinunternehmer), which may always be issued as a sonstige Rechnung. This is a permanent exception, separate from the transition;
  • ordinary invoices to consumers, which are outside the E-Rechnung obligation.

What Revel does

  • No country-specific restriction today: attendee invoicing and online/offline payments are allowed.
  • Gap from 1 January 2027: when a German organizer has attendee invoicing enabled and a buyer with a German VAT ID places an order above 250 EUR gross, Revel issues a plain PDF on the organizer's behalf. For organizers above the turnover threshold, that PDF is no longer a valid invoice. Revel cannot know an organizer's turnover. Two options are tracked in #1232: issue ZUGFeRD (Factur-X EN 16931) invoices via euinvoice (#1234, #1235), or, as a fallback, gate those invoices as SkippedFiscalDocument, as for Belgium.
  • The common ticket content applies.
  • §14 Abs. 1 and 2 UStG: definition of the E-Rechnung (EN 16931, or an agreed format convertible into it); duty for supplies between businesses established in Germany; supplies exempt under §4 Nr. 8 to 29 excluded. Ordinary supplies to consumers need no E-Rechnung. The invoice duty toward consumers is limited to land-related work (§14 Abs. 2 UStG), which is not relevant to ticketing. §14 UStG
  • §27 Abs. 38 UStG: transition. Nr. 1: supplies in 2025–2026, invoice sent by 31 December 2026, paper or another electronic format with consent. Nr. 2: supplies in 2027, invoice sent by 31 December 2027, prior-year Gesamtumsatz (§19 Abs. 2) up to 800,000 EUR. Nr. 3: supplies in 2027, a non-EN 16931 electronic format exchanged via EDI with consent (no paper). §27 UStG
  • §34a UStDV: invoices for supplies exempt under §19 Abs. 1 UStG (Kleinunternehmer) may always be issued as a sonstige Rechnung, notwithstanding §14 Abs. 2 S. 2 UStG. §34a UStDV
  • §33 UStDV: invoices up to 250 EUR gross (whole invoice total) may always be issued as a sonstige Rechnung; S. 3 excludes supplies under §§3c, 6a and 13b UStG. §33 UStDV
  • BMF letter of 15 October 2025 (via secondary sources): XRechnung and ZUGFeRD 2.0.1 or later qualify, except the MINIMUM and BASIC-WL profiles; in a hybrid PDF the XML prevails; e-mail delivery is enough for B2B. taxpunk synopsis, Haufe
  • KassenSichV: the technical security device (TSE) requirement covers electronic recording systems with cash functions only; online shops are out of scope. Source: AEAO zu §146a AO.
  • Summary and further sources: euinvoice country notes

Open questions

  • The primary text of the BMF letter was not retrieved (the BMF site returned errors on 28 October 2026); its content comes from secondary sources.
  • KassenSichV and Revel's at-the-door and offline payments recorded by staff: the AEAO test is about recording systems with a cash function, which can include comparable on-site payments. Pure online sales are out of scope. Whether staff-recorded door payments bring an organizer's setup into scope has not been assessed.
  • §4 Nr. 20 UStG exempts some cultural events (theatres, concerts and similar by public bodies or certified equivalents), whose invoices need no E-Rechnung. Whether to model it or leave it to the organizer.
  • A German VAT ID is used as a proxy for "established in Germany". Whether that is good enough.
  • Ticket-specific or event-specific rules (for example local levies) were not part of this review.

Later layers

  • ZUGFeRD attendee invoices via euinvoice (#1235), on the EN 16931 data foundations (#1234).
  • Fallback gate if that misses 1 January 2027 (#1232).

See #1232.