Germany: E-invoicing obligation from 2025

The e-invoicing requirement is here: With the Federal Council's approval of the Growth Opportunities Act, it is now legally regulated that electronic invoicing will be mandatory for companies in Germany from 2025.

Terminological changes and regulations for receipt of invoices

The new obligation for electronic invoices will generally come into force from January 1, 2025. The changes initially only affect services between companies (B2B) based in Germany. In Germany, a basic distinction will be made between electronic and other invoices.

• Electronic invoice are invoices that are issued, transmitted and received in a structured electronic format and enable electronic processing. The electronic invoice must comply with the European standard (CEN standard EN 16931). The format requirements are met by the XRechnung or the hybrid ZUGFeRD format. However, other formats can also meet the requirements. It should also be noted that in the hybrid invoice format, the structured part must be leading.
• Other invoices refer to paper invoices and other invoices that are sent in another electronic format, such as PDF invoices.
• Important: From 2025, a PDF invoice will no longer be considered an electronic invoice!
• The introduction of a tax reporting system for domestic B2B transactions will follow at a later date in order to combat sales tax fraud.

Receipt of e-invoices

The following applies: from January 1st, 2025 Receipt of e-invoices Mandatory for all invoice recipients for B2B transactions in Germany.

Introduction and transitional regulations for sending e-invoices

For the start from January 1st, 2025, transitional regulations have been set for the years 2025 to 2028:

• Until the end of 2026, executed B2B sales can continue to submit paper invoices. This means that paper invoices can continue to be sent without the consent of the invoice recipient. Other electronic invoice formats (such as invoices as PDF) can only be sent with consent.
• The same regulation applies until the end of 2027, with the addition that billers with a previous year's turnover of 800,000 euros must send electronic invoices. Paper invoices may therefore only be sent by companies that are below the limit. All companies that exceed these limits must send e-invoices, but also have the option of sending other electronic invoices (such as invoices as PDF) using EDI.
• From 2028, the new requirements for electronic invoices will be mandatory for all companies. The BMF is authorized to specify the structured electronic format for e-invoices in more detail by means of a legal ordinance.
• Note: A postponement to 2030 or 2032 is currently being discussed.

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