# German e-invoicing mandate 2027 for Dynamics AX and D365

> Sending from 2027, receiving since 2025: what the BMF clarified and how AX 2009, AX 2012 and D365 F&O send and receive XRechnung and ZUGFeRD invoices.

- Author: Ayse Sevgi Balveren, Balsoft GmbH
- Published: 2026-10-11
- Language: English
- Tags: E-Rechnung, XRechnung, ZUGFeRD, Eingangsrechnung, Dynamics AX 2012, Dynamics AX 2009, Dynamics 365 F&O, Hive BDC
- Canonical: https://balsoft.de/en/blog/e-rechnungspflicht-2027-dynamics-ax-d365

On 1 January 2027 the grace period ends for many companies in Germany. If your German entity had more than 800,000 EUR total turnover in the previous year, its invoices to other businesses in Germany must be e-invoices. A PDF by mail is no longer enough. One year later the obligation applies to everyone.

For companies running Dynamics AX 2009 or AX 2012 this is a special situation. Microsoft no longer ships updates for these versions, and a move to Dynamics 365 is rarely possible before January. This post sums up what applies, what the German Federal Ministry of Finance (BMF) has clarified, what comes next, and how AX and D365 F&O send and receive e-invoices without changing the ERP.

## What applies from 2027

The obligation comes from the German Growth Opportunities Act (Wachstumschancengesetz) and covers invoices between businesses in Germany:

- **Since 1 January 2025** every company must be able to receive and process e-invoices.
- **From 1 January 2027** companies with more than 800,000 EUR total turnover in the previous year must send e-invoices. Paper and PDF are allowed for them only until 31 December 2026. Smaller companies may still use the transition rule in 2027.
- **From 1 January 2028** the obligation to send applies to all companies.

Exempt from issuing e-invoices are, among others, small-amount invoices up to 250 EUR, travel tickets and small businesses under the Kleinunternehmer rule. Small businesses must still be able to receive e-invoices. Invoices to public authorities already go out as XRechnung with a Leitweg-ID, for the federal government since November 2020.

An e-invoice is an invoice in a structured format under the European standard EN 16931 that software can read without retyping. In Germany that mainly means **XRechnung** (pure XML) and **ZUGFeRD** from version 2.0.1, a PDF with embedded XML. The ZUGFeRD profiles MINIMUM and BASIC WL do not count, because they lack mandatory data.

## What the BMF has clarified

With its second letter of 15 October 2025, the tax administration answered a question that matters for ZUGFeRD: **in hybrid formats the XML part counts, not the PDF.** Until then the visible PDF took precedence when the two disagreed. Now every VAT-relevant mandatory field must be complete and machine-readable in the XML. Supporting documents such as a timesheet may be embedded in the e-invoice as attachments. A link to documents stored elsewhere is not enough, and no mandatory field may appear only in an attachment.

This has consequences for recipients too. If a supplier is obliged to send an e-invoice and sends only a PDF, your input VAT deduction can be at risk. Incoming e-invoices must also be checked technically, ideally before payment. Not every finding costs the deduction: errors in the VAT-relevant mandatory fields can, a wrong IBAN or a missing buyer reference usually does not. Hive BDC runs this check before the invoice reaches the ERP and reports every finding with its rule ID. The section on incoming invoices below shows how.

For sending, this means a nice PDF from the ERP with some XML next to it is not enough. Invoice number, description of the supply, tax rates, amounts and the buyer and seller data must arrive cleanly in the XML. If something is missing there, the invoice is not a proper e-invoice, even when the PDF is right.

## What comes next

The formats keep moving, and you should plan for that:

- **ZUGFeRD 2.5.2** (technically identical to Factur-X 1.09.2) has applied since 1 September 2026. It mainly corrects calculation and line rules.
- **XRechnung 3.0.2** is the current version and stays valid until at least 31 July 2027.
- **XRechnung 4.0**, based on the revised EN 16931-1:2026, is available as a preview and expected in spring 2027. It adds fields, for example several purchase order references in one invoice.
- **ViDA**, the EU package "VAT in the Digital Age", introduces electronic reporting for cross-border B2B supplies from 1 July 2030. Germany plans its own reporting system for it.

So if you introduce a solution today, make sure new versions arrive as updates and not as a new project.

## Where Dynamics AX and D365 F&O stand

Microsoft ended extended support for **Dynamics AX 2009 on 12 April 2022** and for **Dynamics AX 2012 R3 on 10 January 2023**. Nothing for e-invoicing will come from Microsoft for these versions, neither for sending nor for receiving. That does not mean you have to move to Dynamics 365: **with Hive BDC, AX 2009 and AX 2012 produce XRechnung and ZUGFeRD without an upgrade and without touching your invoice layouts, and your suppliers' e-invoices arrive in AX as vendor invoices.** Your AX system keeps running, and the e-invoicing obligation is met on both sides.

**Dynamics 365 Finance & Operations** comes with its own Electronic Invoicing building blocks. Sending to customers, filing in document management and the many other documents the ERP prints usually remain yours to solve. **Hive BDC covers the whole way for D365 F&O as well:** produce, check, send and file the e-invoice together with every other document, and on the incoming side read and check your suppliers' e-invoices and create the vendor invoice.

## Accounts receivable (AR): how Hive BDC produces the e-invoice

Hive BDC (Balsoft Data Connector) is our product for exactly this case. It runs on a Windows server in your network and works in both directions: outgoing invoices to your customers (AR) and incoming invoices from your suppliers (AP). For outgoing invoices it picks up the invoice where Dynamics has posted it:

1. **Post the invoice in Dynamics**: Posting works as usual in AX 2009, AX 2012 or D365 F&O. Your invoice layouts stay as they are.
2. **Export through the Data Flow module**: A batch job writes the invoice data as JSON and the printed PDF into an export folder.
3. **Check and convert**: Hive BDC checks the invoice against the business rules of EN 16931 and XRechnung and produces XRechnung 3.0.2 or ZUGFeRD 2.5.2. In ZUGFeRD the same XRechnung XML sits inside the PDF, so the XML is complete, as the BMF requires.
4. **Send and file**: The e-invoice goes to the customer from your own Microsoft 365 mailbox. If you want, it is also filed in your DMS, for example SharePoint.

The dashboard shows at any time whether the service is running, whether the licence is valid and which documents went out last:

![Hive BDC dashboard with the service running, a valid licence, the number of exports and a list of recently exported documents, including a sales invoice in xrechnung format](https://balsoft.de/blog/e-rechnungspflicht-2027-dynamics-ax-d365/hive-bdc-dashboard.webp)

*The Hive BDC dashboard with demo data: service, licence, exports and the documents sent last, the sales invoice as XRechnung.*

You choose in the settings which document types Hive BDC handles. The sales invoice becomes the e-invoice; order confirmations, quotations, collection letters, purchase orders and payment advices go out as PDF. Whether a customer gets XRechnung, ZUGFeRD or no e-invoice is set per customer in the ERP.

![Hive BDC settings, document types tab: sales invoice as e-invoice for two companies, order confirmation, quotation, collection letter, purchase order and payment advice as PDF](https://balsoft.de/blog/e-rechnungspflicht-2027-dynamics-ax-d365/hive-bdc-settings-doctypes.webp)

*Document types in the settings: the sales invoice is produced as an e-invoice, the other documents as PDF, each per AX company.*

Before an invoice goes out, it is checked. If, for example, the Leitweg-ID of a public-sector customer or a seller contact is missing, the log shows it with the official rule ID, such as `BR-DE-15`. That tells you which master data still needs to be added in the ERP.

## Accounts payable (AP): how the e-invoice gets into the ERP

Since 1 January 2025 your suppliers have been sending XRechnung and ZUGFeRD invoices, and their number grows with every stage of the obligation. An XRechnung is pure XML that nobody can read without suitable software, and retyping it in accounts payable takes time. Hive BDC picks up the e-invoice and brings it into Dynamics as a vendor invoice:

1. **Receive the e-invoice**: The invoice arrives in your invoice mailbox in Microsoft 365, a folder, your DMS (for example SharePoint) or over Peppol. Hive BDC picks it up from any of these inputs.
2. **Read and check**: Hive BDC reads XRechnung and ZUGFeRD in both syntaxes, CII and UBL, checks the invoice against EN 16931 and recalculates the totals. If something does not match, the finding is logged with its rule ID.
3. **Hand over to Data Flow**: The checked invoice data goes as JSON to the Data Flow module in your Dynamics.
4. **Vendor invoice in Dynamics**: Depending on your setup, Data Flow creates a pending vendor invoice, a purchase order invoice or an invoice journal. Your accounting team reviews and posts as usual in AX 2009, AX 2012 or D365 F&O.

Supplier invoices reach the ERP without retyping, and the technical check the BMF expects is done before anyone approves the invoice.

## What to do now

Only a few weeks are left until January. Settle these points by then:

1. **Check your 2026 total turnover.** If it is above 800,000 EUR, the obligation to send applies to you from 1 January 2027.
2. **Organise receiving and checking.** Since 2025 you must be able to accept e-invoices. Check whether your incoming process can read and technically validate XRechnung and ZUGFeRD rather than just display the PDF, and who resolves findings with the supplier. With Hive BDC, incoming e-invoices arrive in Dynamics checked and as vendor invoices.
3. **Complete the master data in the ERP.** Leitweg-IDs of public-sector customers, an invoice e-mail address per customer, a contact with phone and e-mail on your side.
4. **Choose the format per customer.** XRechnung for authorities and customers who want XML, ZUGFeRD for everyone who also expects a readable PDF.
5. **Test with real invoices.** Run some invoices from the test system through the check and send them to test recipients before you go live.
6. **Plan the archive.** E-invoices must be kept in their original format, unalterable and machine-readable. A printout is not enough. Decide where the XML is stored, for example in your DMS such as SharePoint.

> **Note:** This post describes the legal situation as we understand it in October 2026 and is not tax advice. For your specific situation, please talk to your tax advisor.

## Further reading

How sending and receiving e-invoices works in your version is shown on our pages [e-invoicing for Dynamics AX 2012](https://balsoft.de/en/e-rechnung/dynamics-ax-2012), [e-invoicing for Dynamics AX 2009](https://balsoft.de/en/e-rechnung/dynamics-ax-2009) and [e-invoicing for D365 F&O (D365FO)](https://balsoft.de/en/e-rechnung/dynamics-365-finance-operations). System requirements, setup and user guide are on [Hive BDC](https://balsoft.de/en/products/hive-bdc).

Sources: [Second BMF letter on e-invoicing, summary by IHK Hannover (German)](https://www.ihk.de/hannover/hauptnavigation/recht/aktuell3/bmf-veroeffentlicht-zweites-anwendungsschreiben-zur-e-rechnung-6797148), [ZUGFeRD 2.5.2 at FeRD (German)](https://www.ferd-net.de/aktuelles-veranstaltungen/aktuelles/news/zugferd-252-veroeffentlicht), [XRechnung 4.0 at KoSIT / xeinkauf (German)](https://xeinkauf.de/aktuelles/xrechnung/xrechnung-4-umsetzung/), Microsoft Lifecycle for [AX 2009](https://learn.microsoft.com/en-us/lifecycle/products/dynamics-ax-2009) and [AX 2012 R3](https://learn.microsoft.com/en-us/lifecycle/products/dynamics-ax-2012-r3).