EU Deadline Radar

What changes in Germany on 1 January 2028

Several compliance deadlines fall on the same day in Germany. Here is what changes on 1 January 2028 and what your company needs to do about each one.

What changes on this date

RegulationDeadline
EU-wideCSRD

CSRD after Omnibus I: sustainability reporting only for 1,000+ employee companies from FY2027; SMEs out of scope with VSME value-chain cap

The Omnibus I package cut CSRD scope to companies with more than 1,000 employees and over €450M turnover; listed SMEs are removed entirely. Large customers may not demand more sustainability data from suppliers below 1,000 employees than the voluntary VSME standard. In-scope companies report for financial year 2027 in 2028.

Large companies: confirm whether you exceed both thresholds and prepare ESRS-based reporting for FY2027. SMEs: use the VSME standard as your maximum response to customer ESG questionnaires and decline requests going beyond it; consider a lightweight VSME report to keep bank and customer relationships smooth.

Details →

GermanyGermany e-invoicing

Germany: all businesses must issue B2B e-invoices

The last transition step: from 1 January 2028 every German business, regardless of turnover, must issue structured e-invoices for domestic B2B supplies. EDI procedures must also be EN 16931-compatible by then.

Move to an invoicing tool that outputs XRechnung or ZUGFeRD, check that your EDI connections can extract EN 16931 data, and inform customers of your e-invoice delivery method.

Details →

EU-wideCSRD

CSRD after Omnibus I: sustainability reporting only for 1,000+ employee companies from FY2027; SMEs out of scope with VSME value-chain cap

The Omnibus I package cut CSRD scope to companies with more than 1,000 employees and over €450M turnover; listed SMEs are removed entirely. Large customers may not demand more sustainability data from suppliers below 1,000 employees than the voluntary VSME standard. In-scope companies report for financial year 2027 in 2028.

Large companies: confirm whether you exceed both thresholds and prepare ESRS-based reporting for FY2027. SMEs: use the VSME standard as your maximum response to customer ESG questionnaires and decline requests going beyond it; consider a lightweight VSME report to keep bank and customer relationships smooth.

Details →

GermanyGermany e-invoicing

Germany: all businesses must issue B2B e-invoices

The last transition step: from 1 January 2028 every German business, regardless of turnover, must issue structured e-invoices for domestic B2B supplies. EDI procedures must also be EN 16931-compatible by then.

Move to an invoicing tool that outputs XRechnung or ZUGFeRD, check that your EDI connections can extract EN 16931 data, and inform customers of your e-invoice delivery method.

Details →

All calendars