Germany's issuing obligation starts in January

The general transitional rule runs to 31 December 2026. A second transitional rule extends that latitude to 31 December 2027 where the issuer's turnover in the preceding year did not exceed EUR 800,000. Read forward, that produces two start dates: 1 January 2027 for issuers above the threshold, and 1 January 2028 for those at or below it. A separate rule allows an EDI procedure that does not itself meet the e-invoice requirements to continue until the end of 2027.

Several categories sit outside the obligation altogether, including small-amount invoices up to EUR 250, travel tickets, supplies exempt under the relevant provisions of the VAT Act, supplies made by businesses under the small-business regime, and supplies to recipients who are not taxable persons. Useful as those are, they are entity-level and transaction-level facts that somebody has to establish and record, one German company at a time.

A group with German holding companies, property vehicles and a management company gets a different answer for each of them. The threshold looks at the turnover of the issuer in the preceding year, so it is tested per taxable person. A management company charging fees across the structure may sit well above EUR 800,000 while the GmbH holding a single building sits far below it, and the two therefore start issuing structured invoices a year apart.

Two complications follow. Where a VAT group exists, the identity of the taxable person is not obvious from the company register, and that has to be settled before anyone assumes the threshold is measured on a subsidiary's own turnover. And the turnover figures that decide the answer for 2027 are 2026 figures, being earned now and confirmed by an accountant months after the date they determine. Nobody outside the group can see the figure, so nobody outside the group will tell you which side of the line an entity landed on.

The finance system cannot answer this on its own. It holds transactions, and the question is about a governed list of legal entities and their attributes. What is needed against each German entity is a small set of recorded facts: whether it is established in Germany for these purposes, whether it belongs to a VAT group and which entity is the taxable person, its prior-year turnover against the EUR 800,000 threshold, whether it issues invoices at all and through whom, and the date its issuing obligation therefore begins.

Those facts move, so the work is a review and never a project. Once the 2026 figures are final, every German entity's start date is confirmed or shifted, and the ones that cross the threshold for the first time acquire a deadline they did not have the year before. A new acquisition arrives with an unanswered version of the same list. Recording who established each answer, and when, is what keeps the next round a review and stops it becoming a fresh investigation. It also settles the awkward question that arises when an obligation is missed, which is rarely what the rule said and almost always who was supposed to be watching it.

An e-invoicing start date is a compliance obligation attached to a specific German entity. The turnover position and the VAT group status are attributes of that entity, the access point or service agreement is a document filed against it, and the audit trail records who established each answer and when. So the group can put the question the way it actually arises: show every German entity, its issuing start date, and the evidence behind the threshold answer. Alethia computes no turnover, issues no invoices and files nothing with a tax administration. What it takes out of the year is the meeting where finance and tax each arrive with a different list.