Germany’s New B2B E-Invoicing Requirements

The German Ministry of Finance (BMF) published a draft guideline detailing the upcoming mandatory B2B e-invoicing. It covers the first requirements, effective from January 1, 2025, under which all resident taxpayers must be able to receive structured e-invoices for domestic B2B transactions.

The key points from the guideline are:

• The MoF plans to launch an e-reporting system for invoice details at a later date, with no specific timeline set.
• Certain invoices are exempt from e-invoicing, including tax-free services, invoices under 250 Euro and travel tickets.
• E-invoices must adhere to EN 16931 syntaxes or a mutually agreed format that meets the requirements. They can be either structured or hybrid with a human-readable part. In case of discrepancies, the electronic data takes precedence. Accepted formats include XRechnung, ZUGFeRD (from version 2.0.1), and international standards such as Italy’s FatturaPA and France’s Factur-X.
• E-invoices can be transmitted via email, electronic interfaces, or portals, but not on USB sticks.
• If recipients cannot accept e-invoices, they cannot demand alternatives. Issuers meet their VAT obligations if they make documented efforts to send e-invoices.
• Any corrections to invoices must be done electronically.
• The final version of the BMF guideline is planned for publication in Q4 2024. Businesses should promptly initiate their e-invoicing implementation projects to meet the January 2025 deadline.

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