Guidance for Jan 2025 initial requirement to receive B2B structured e-invoices
Germany’s Ministry of Finance (BMF) on 19 November 2024 issued new Frequently Asked Questions on first phase launch of its e-invoicing mandate – 1 January 2025. Following a 2025 to 2028 phased introduction (see below), all resident businesses must issue structured e-invoices (EN16931 or similar) for domestic transactions. There is no requirement to also report to the tax authorities or pre-clearance.
From 1 January 2025, suppliers may opt to send e-invoices and their customers must be able to accept them. The minimum e-invoicing requirements per BMF is “The provision of an e-mail inbox is sufficient for the receipt of an e-invoice” Alternatively, taxpayer counter parties may agree on other electronic data exchange methodologies.
Germany e-invoicing requirements
Germany is introducing the e-invoicing requirements based on the 2024 Growth Opportunities Act Wachstumschancegesetz, and then supported by October issued final letter (update of a June draft).
When is an e-invoice required to be issued?
Sales structured e-invoices are required of taxpayers established in Germany only. So if a German resident taxpayer sales goods domestically, EU intra-community or export, then they must produce a compliant e-invoice. Foreign businesses with a German fixed establishment (e.g. leased warehouse space) are included.
All German resident businesses must be able to receive e-invoices from 1 January 2025. Non-compliant e-invoices will not be eligible for deduction by the customer without further application to the tax authorities. E-invoices must be securely held for eight years – 10 years for other accounting records.
The following transactions are excluded from e-invoicing and may continue to be paper or PDF-based:
- Foreign businesses supplier with no German establishment;
- Simplified invoices (below €250);
- Travel tickets;
- Micro businesses (below €100k sales per annum 2025) only have to receive e-invoices (so not send);
- B2C; and
- VAT exempt transactions
What format of e-invoice is acceptable
Germany requires machine readable e-invoices based on the Directive 2014/55/EU (CEN format EN 16931) standard. This includes:
- XRechnung
- ZUGFerd 2.0.1 or later hybrid
- Other recognised formats, e.g. French Factur-X or Peppol BIS
- EDIFACT protocol if still meets EU16931
Additional information beyond the minimum German VAT invoice requirements may be added, including invoice attachments, contracts or similar.
Council of EU approves mandatory German e-invoicing
The request by the European Commission on behalf of Germany to introduce mandatory B2B domestic VAT e-invoicing was approved by the Council of the European Union on 25 July. This allows Germany to impose real-time e-invoicing which it is now proposing for 1 January 2025 to 2028.
The request was backed by the EU Commission in June (see below) to authorise Germany to derogate from the EU VAT Directive and its requirement for paper-based invoices. Germany will be permitted to impose e-invoices until the end of 2027 when there will be a further review.
Learn about VATCalc’s VAT e-invoicing product, which not only creates and submits e-invoices to global tax authorities, but is unique in providing full audit against local tax legislation. And since it is built on the same application as our VAT Filer, all of your sales or purchase e-invoices are fully reconciled to your VAT returns.
Germany’s application to the EC lasts until December 2027. However, the EU is proposing to remove this requirement to seek its approval to deviate from the EU VAT Directive on e-invoicing from 2025 This is part of the ViDA reforms.
Read more about German VAT in our national guide.
Germany B2G e-invoices
As per the requirements of the EU VAT Directive on e-invoicing, in April 2020, Germany mandated the acceptance of electronic invoices for Federal governmental transactions with the commercial sector, B2G.The format varies by state (Bundesland) as they adopt the legislation in their local laws. The states have the option of their own format (which should be PEPPOL compliant) or the recommended by Core Invoice User Specification (CIUS).
