From 1 January 2027, the German tax authorities will as a rule make tax assessment notices available electronically for retrieval instead of sending them by post. Anyone who wants to keep receiving notices on paper has to apply for it. The basis is the revised § 122a AO of the Abgabenordnung, the German Fiscal Code, introduced by the Fourth Bureaucracy Relief Act (“Viertes Bürokratieentlastungsgesetz”) of 23 October 2024. Consent to electronic notification is no longer required.
The provision has been in force since 1 January 2026, but its core only takes effect a year later. Under Art. 97 § 28 Abs. 2 EGAO, the rule that notices are to be served electronically applies for the first time to notices issued after 31 December 2026. The change was originally planned for 2026; an act of 22 December 2025 amending the Minimum Tax Act postponed it by one year. In the current year, therefore, only those who have given their consent receive notices electronically. Everyone else still receives them by post in 2026.
Who receives the notice from 2027
Notices are made available through ELSTER, the online portal of the German tax authorities. Where a notice goes depends on who filed the return and whether an authority to receive notices (“Empfangsvollmacht”) has been submitted electronically. The Federal Ministry of Finance set out the details in its letter of 13 August 2026 (IV D 1 - S 0284-a/00002/011/237).
| Situation | Service | Basis |
|---|---|---|
| The adviser filed the return and their authority to receive notices is on record electronically | electronically to the adviser | § 122a Abs. 1 Satz 2 Nr. 2 AO |
| The company filed the return through its own ELSTER account | electronically to that ELSTER account | § 122a Abs. 1 Satz 2 Nr. 1 AO |
| Neither an active ELSTER account nor an authority to receive notices submitted electronically | still by post | BMF letter, para. 2 |
| Application for service by post made | by post | § 122a Abs. 2 AO |
At present, electronic service is technically possible nationwide only for income tax, corporate income tax and trade tax (“Gewerbesteuer”). VAT notices and notices of separate determination (“Feststellungsbescheide”) will continue to be sent by post for the time being. There is no entitlement to electronic service: the tax office may depart from it for technical or organisational reasons.
The deadline runs from the date the notice is made available
A notice made available for retrieval is deemed to be served on the fourth day after it is made available (§ 122a Abs. 4 AO). The one-month deadline for an objection (“Einspruch”, § 355 Abs. 1 AO) runs from that day. The tax authorities do send an e-mail notification on the day the notice is made available, but according to the BMF letter it now serves only as a reminder. Whether and when anyone opens the notice makes no difference to the deadline.
For companies based outside Germany, this is a noticeable change. A notice sent by post to an address abroad is only deemed to be served one month after it was posted (§ 122 Abs. 2 Nr. 2 AO). § 122a Abs. 4 AO, by contrast, makes no distinction between Germany and abroad: in both cases, the fourth day after the notice is made available is decisive. The time until the objection deadline expires is therefore shortened by almost a month.
Paper remains available, but only on application
Anyone who wants to keep receiving notices by post applies for service by post (§ 122a Abs. 2 AO). The application takes effect when the tax office receives it and applies only to the future; what matters is that it is on record before the notice is made available. The BMF recommends filing the application through ELSTER. Advisers who submit their powers of attorney electronically can also file it through the power of attorney database of the Bundessteuerberaterkammer, the federal chamber of tax advisers. The application and its withdrawal each apply uniformly to all notices under the same tax number (“Steuernummer”).
Not having consented to electronic service so far does not count as an application for paper. Without an express application, notices will be served electronically from 2027 (BMF letter, para. 4). If an application coincides with the date on which a notice is made available, the notice may also be served electronically despite the application. If it was not retrieved in time for that reason, the BMF considers reinstatement of the missed deadline possible (§ 110 AO).
What the draft Annual Tax Act 2026 would change
The government draft of the Annual Tax Act 2026 (“Jahressteuergesetz 2026”) provides for further changes to § 122a AO, also to apply from 1 January 2027 (Bundestag Drucksache 21/8283, Art. 19 No. 3 and Art. 21). They have not yet been adopted; the draft is before the Bundestag.
- Electronic service regardless of how the return was filed: An active user account of the company with the tax authorities would be sufficient, unless a different authority to receive notices exists. How the return was filed would no longer matter.
- Applications for paper only electronically: They could only be made through a user account of the tax authorities, through software using the official interface or through the power of attorney database of the Bundessteuerberaterkammer. According to the explanatory memorandum, an e-mail is not sufficient.
- Paper applications would no longer count: Applications made on paper up to that point would not be taken into account for notices from 2027 (Art. 97 § 28 Abs. 3 EGAO as drafted).
- Permanent applications only: The application would apply without a time limit until it is withdrawn.
Anyone who wants to keep receiving notices on paper should therefore file the application through ELSTER now. It will then be effective under the current law as well as under the draft.
What companies should arrange now
- Decide on the recipient: Clarify whether notices should go to the tax adviser or to the company’s own ELSTER account, and whether the authority to receive notices has been submitted electronically.
- Check the access: Who in the company holds the ELSTER access, is it valid, and does the notification reach an address that is also read during holidays or after a change of staff?
- Adjust deadline monitoring: Calculate deadlines from the date the notice is made available, not from the arrival of a letter. Where notices used to go abroad, there is almost a month less time.
- Arrange forwarding and filing: Decide who retrieves notices, passes them on to group headquarters and files them.
- Make a deliberate choice about paper: Anyone who wants to keep receiving post files the application electronically, before the first notice is made available.
FRADECO receives your notices for you
Where we hold the authority to receive notices, they come to us directly, from 2027 as a rule electronically. We check them, keep the objection deadline in view and come back to you when something needs to be done. We submit the power of attorney electronically through the database. How this works is explained in our question on the power of attorney, and our support with returns, deadlines and the tax office under German Tax & Compliance.
Information current as of 16 October 2026, based on § 122a AO and Art. 97 § 28 EGAO, the letter of the Federal Ministry of Finance of 13 August 2026 (IV D 1 - S 0284-a/00002/011/237) and the government draft of the Annual Tax Act 2026 (Bundestag Drucksache 21/8283).