Germany’s B2B E-Invoicing Mandate: Key Requirements

BMF publishes new “letter” on mandatory B2B e-invoicing being phased in 2025 – 2028

Germany’s Ministry of Finance (BMF) on 15 October 2024 issued a final letter (update of June draft) detailing the scope and regulations for the upcoming launch of mandatory B2B e-invoicing for resident businesses. The phased implementation will take place from 1. Januar 2025, through January 1, 2028. Here are the main points:

Key Aspects of the B2B E-Invoicing Mandate

• Phased Implementation:
  • 1. Januar 2025: All businesses must be capable of receiving structured e-invoices that comply with the EN16931 standard. Buyer consent will no longer be necessary for receiving e-invoices.
  • January 1, 2027: Businesses with an annual turnover exceeding €800,000 must issue only EN16931-compliant e-invoices.
  • January 1, 2028: The mandate will cover all businesses, requiring them to both issue and receive e-invoices exclusively.

• Scope and Formats:
  • E-invoices must comply with the EN16931 standard or an agreed-upon alternative format that allows proper VAT data extraction. Accepted formats include XRechnung, ZUGFeRD, and other EN16931-compatible formats.

• Transmission and Compliance:
  • E-invoices can be sent via email, electronic interfaces, or portals. Physical media (e.g., USB sticks) are not allowed. Recipients are responsible for ensuring compliance, and non-compliant invoices, such as PDFs or paper, will not be valid for tax deductions.

• Exemptions:
  • Exemptions apply to tax-free services, invoices under €250, and small-value invoices, which can continue to be issued as paper invoices until December 31, 2026.

• Corrections and Documentation:
  • Any corrections to e-invoices must also be submitted electronically.