Invoicing & funding
The 2027 e-invoicing duty for civil engineering firms: what actually applies
Receiving since 2025, sending from 2027 or 2028: the deadlines, the €800,000 threshold, and what additionally applies to firms with public clients.
From when must a civil engineering firm send e-invoices?
In short: you have had to be able to receive them since 01.01.2025. Sending depends on the previous year’s turnover – over €800,000 from 01.01.2027, below that from 01.01.2028.
Anyone working for public clients is usually affected long since anyway: separate, earlier rules apply there, and in practice the Straßenbauamt requires the XRechnung regardless of these B2B deadlines.
The deadlines at a glance
| What | From | For whom |
|---|---|---|
| Being able to receive e-invoices | 01.01.2025 | all domestic businesses |
| Sending e-invoices | 01.01.2027 | previous-year turnover over €800,000 |
| Sending e-invoices | 01.01.2028 | everyone else – paper and PDF remain permitted until 31.12.2027 |
| XRechnung to federal authorities | 27.11.2020 | anyone invoicing the federal government |
The €800,000 threshold refers to the issuer’s total turnover in the preceding calendar year. It is therefore a snapshot: a firm just above it in 2026 falls under the earlier deadline in 2027.
Sources: BMF – e-invoicing FAQ · BMF circular of 15.10.2025
What counts as an e-invoice – and what does not
An e-invoice within the meaning of the rules is a structured data set to EN 16931. In practice that means XRechnung or ZUGFeRD.
Explicitly not covered:
- a PDF sent by email
- a scanned paper document
- a photo of the invoice
- ZUGFeRD in the MINIMUM and BASIC-WL profiles
The last point surprises many: not every ZUGFeRD profile meets the requirement. If your invoicing program can do ZUGFeRD, ask which profile.
What this means with a public client
For firms in road construction and Tiefbau, the B2B discussion is often secondary, because the clients are authorities anyway. There:
- Federal authorities have required the XRechnung since 27.11.2020.
- States and municipalities have their own deadlines and their own portals. For a Straßenbauamt that is the case that decides in practice – and it has to be checked per federal state.
That is not an evasion but the legal position: there is no nationwide answer here that could be printed on a vendor’s page.
The most common misconception: “we need construction software for that”
No. Producing an XRechnung is no great feat and no reason to buy industry software. There are one-off tools for it, invoicing programs for a few euros a month, and a free federal portal.
The effort in a civil engineering firm lies elsewhere – in the chain before the invoice:
- Take over the bill of quantities (GAEB)
- Price the items
- Capture the Aufmaß from site
- Check and approve the quantities
- Assign the quantities to the items
- Produce the invoice
Step 6 is the easiest. Buying software solely because of the e-invoicing duty is buying the wrong solution for the wrong problem.
What you actually have to do before your deadline
| Task | Effort | When |
|---|---|---|
| Secure receiving (inbox, responsibility) | low | should be done |
| Clarify the format per client | low, but per customer | before the first invoice |
| Maintain the Leitweg-ID in your master data | low | before the first invoice |
| Decide the sending route (portal, mail, Peppol) | medium | a few months ahead |
| Involve your tax adviser | low | early |
The list is deliberately short. For most firms the e-invoicing duty is an organisational matter, not a major technical project.
Version status: 3.0.2, with 4.0 coming
What currently applies is XRechnung 3.0.2 (as of August 2026). Version 4.0 implements the revised EN 16931-1:2026 and has been announced for mid to late 2026, with a transition period for 3.0.2.
For your firm that is a question for your software vendor, not for you: whoever produces the invoice has to follow the version change.
Frequently asked
We are a small business under § 19 UStG. Does this apply to us too? Not for issuing: small businesses under § 19 UStG are permanently exempt from the obligation to issue e-invoices. They are not exempt from the obligation to receive them – that has applied to all domestic businesses since 01.01.2025. These two sentences are the ones most often confused. Whether § 19 applies to your firm is for your tax adviser to say; this page does not replace them.
Is it enough if our tax adviser writes the invoices? If they do that anyway, yes. But check whether the supporting documents – take-off sheets, call-off reference – go with them. With public clients that is exactly what payment hangs on.
Do we have to archive e-invoices? Yes, with the usual retention periods and in the original format. A printout is not enough.
What if a customer still wants paper? In B2B that is possible up to your deadline. After that the law decides, not the customer’s preference.
Your deadline in four questions
Instead of a general overview, the concrete placement. Four questions, in this order:
1. Do you invoice public clients? If yes, the 2027 question is largely settled for you – the XRechnung is as a rule already required there today. You are effectively in the target state and only have to catch up on the B2B part.
2. Was your previous-year turnover over €800,000? If yes, 01.01.2027 applies to your B2B invoices. If no, 01.01.2028 – until 31.12.2027 you may keep issuing paper and PDF.
3. Can you receive and archive e-invoices? This obligation has existed since 01.01.2025 and is overlooked more often than the sending duty. An inbox is not enough – the invoice has to be retained in its original format.
4. Who produces your invoices today? If your tax adviser invoices, settle with them whether and how they supply the supporting documents – take-off sheets, call-off reference. With public clients payment hangs on exactly that, and it is exactly what a payroll office does not see.
Archiving: the underestimated part
An e-invoice is a structured data set, not a document. For retention that means:
| Requirement | What it means in practice |
|---|---|
| Keep the original format | The XML file, not a printout and not a PDF of it |
| Immutability | Storage in which files cannot be overwritten |
| Findability | Assigned to job and client, not just by date |
| Readability over the retention period | The file must still be displayable in eight years |
The first point is the most common mistake: filing the XRechnung only as a PDF preview means not having archived it. Settle with your tax adviser where the original sits – with you or with them.
What to ask your tax adviser
This page does not replace tax advice. But it can give you the questions to walk in with:
- Is our previous-year turnover above or below the €800,000 threshold – and what exactly counts towards it?
- Who archives the e-invoices in their original form, you or us?
- How will our outgoing invoices be produced in future, and who checks them before sending?
- What happens to incoming invoices that reach us as XRechnung?
- Are there special cases in our setup – small-amount invoices, credit notes, prepayments?
Question 5 is worth asking: different rules apply to certain invoice types, and assessing that is your adviser’s job, not your software vendor’s.
What this means for choosing software
The most common wrong decision in this context is buying industry software because of the e-invoicing duty. The duty concerns a file format; construction software solves a workflow problem. Those are two different reasons to buy.
| If your problem is … | … then what you need is |
|---|---|
| “We cannot produce an XRechnung” | an invoicing program or the portal |
| “We do not know whether our invoice arrives” | a check of the Leitweg-ID |
| “Assembling the invoice takes days” | an unbroken chain from take-off to invoice |
| “We cannot find the supporting documents” | quantities tied to their source document |
Only the bottom two rows justify construction software. Buying because of the top two means paying for features you do not need.
Incoming invoices: the duty that already applies
Much is written about sending, little about receiving – yet it has been mandatory since 01.01.2025 and applies to you regardless of turnover thresholds.
What that involves in practice:
- An address someone reaches. An inbox somebody reads, not an info@ address nobody opens.
- Processing without a media break. Printing an XRechnung and filing it does not serve the purpose – the original is the file.
- Making it readable. You must be able to look at the invoice. A viewer is enough for that; an expensive system is not needed.
- Checking as before. On the facts and the arithmetic – the format changes nothing there.
The most common stumbling block is point 1: suppliers switch over, send to the address in their master data, and nobody reads it there. The invoice counts as delivered, the deadline runs, and the reminder arrives before anyone has seen the invoice.
Reconciling your own invoice-receipt address with your largest suppliers is half an hour’s work and prevents exactly that.
Does anything change for a firm whose German is limited?
Not for the obligations – the deadlines are the same for everyone. Two practical things do change.
First: incoming XRechnungen arrive with German field names, but their content is figures. A viewer makes that readable; learning once which field is which is enough.
Second, and more important: the authority writes in German. If your invoice is rejected, the reason arrives in German too – and usually points at a single field. That is why checking the mandatory fields before the file leaves the house is cheaper than reading the reason afterwards.
In summary
For civil engineering firms with public clients, e-invoicing has long been everyday business; the B2B deadlines of 2027 and 2028 are more of a formality for them. More important than the date is the realisation that the invoice is the easiest part – and that software which only solves it does not touch the actual problem.
The technical details of addressing are in the article XRechnung to the Straßenbauamt ; how the invoice arises in Levora from the approved quantities is on the page about XRechnung and ZUGFeRD .
Find out where you actually stand
Twenty minutes about your clients and last year’s turnover are enough to place your deadline – and to see whether there is anything to do about it at all.
Request a demo