Germany's new e-invoicing rules: what self-storage operators need to know
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Introduction
This is a fast-moving area of regulation. This article reflects our understanding of the rules as of August 2026, based on guidance from the German Federal Ministry of Finance (BMF). We will update it as the rules develop.
Germany is changing how businesses issue invoices to each other. If you operate in Germany, this affects some of your invoicing, on a fixed timeline. Here is what is confirmed, and what it means in practice.
Two dates matter
1 January 2027: businesses with a total turnover above €800,000 in the previous year (2026) must issue structured electronic invoices for domestic B2B transactions.
1 January 2028: this obligation applies to every business in Germany, regardless of turnover.
There is also a date already behind us. Since 1 January 2025, every business in Germany has had to be able to receive e-invoices. This side is simple to satisfy: a normal email inbox is enough.
What counts as an e-invoice
A PDF invoice is not an e-invoice, even though it looks like a normal document. The law requires a structured, machine-readable format that follows the EN 16931 European standard. In practice this means one of two formats:
ZUGFeRD: a PDF that looks like a normal invoice to a human, with the structured data embedded invisibly inside the same file.
XRechnung: a pure data file, with no PDF at all. It is built for accounting software to process automatically.
Until 31 December 2026, businesses can still send paper or plain PDF invoices, as long as the recipient agrees to it. From the relevant date above, that flexibility ends.
Who this applies to
The obligation only covers domestic German B2B invoices: invoices from one German business to another, where VAT applies.
It does not apply to:
- Invoices to private customers (B2C)
- Invoices under €250 gross
- Invoices where the tenant is based outside Germany
- Rentals that are VAT-exempt and have not been opted into VAT
Self-storage unit rentals are, by default, VAT-exempt under German law. Many operators opt their business tenants into VAT, in which case those invoices are affected. Whether your unit rentals fall inside or outside the mandate depends on your VAT setup, so this is worth confirming with your tax advisor if you are unsure.
The €800,000 threshold is about your whole business, not just storage
This is the detail that catches people out. The threshold is based on your total business turnover, not your self-storage revenue and not the turnover from any one supplier or platform you use. If your business has other revenue streams alongside self storage, all of it counts towards the €800,000 figure.
What happens if an invoice is not compliant
Two consequences follow a non-compliant invoice for an in-scope transaction:
- A fine of up to €5,000 per invoice under §26a UStG.
- Your business customer cannot deduct the VAT on that invoice. In practice, this means business customers are likely to simply refuse non-compliant invoices, because it costs them money to accept one.
The second point matters more day to day. Even without any enforcement action, your business customers will ask for a compliant invoice, because their accountant will reject anything else.
Where this leaves operators
Whether your business falls into the 2027 wave or the 2028 wave depends on your total 2026 turnover, and whether a given invoice is affected depends on your VAT setup. Both are specific to your business, which is why we have not tried to summarise them into general rules here. Your accountant or tax advisor will be able to confirm both for your business.
What this means for Kinnovis customers
We have been in dialogue with a number of our existing customers on this topic, which has led to this article. Our Product & Engineering Team is best prepared to ensure these requirements are fulfilled before the regulations come into effect.
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