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Germany Introduces Countrywide E-Invoicing Mandate Starting in 2025

Germany Introduces Countrywide E-Invoicing Mandate Starting in 2025

Germany has been working towards legislating an e-invoicing obligation for business transactions for a long time. With the approval from the Bundesrat, the introduction of mandatory B2B e-invoicing will officially begin on January 1, 2025.

The Bundesrat, Germany’s legislative body representing the Federal States, has approved the Growth Opportunities Act (Wachstumschancengesetz), mandating B2B e-invoicing. The German Parliament (Bundestag) had already voted in favor of the changes in the Act as suggested by the German Mediation Committee on February 23. Therefore, the Growth Opportunities Act has now been passed, and e-invoicing in the business sector will become obligatory in Germany as of January 1, 2025.

The mandatory use of electronic invoices will be a prerequisite for the obligation to report transaction-related data of B2B sales to a standardized national electronic administrative system (reporting system) at a later date.

Implementation Timelines

January 1, 2025: EN-compliant e-invoices become the default in Germany.

  • Businesses must be prepared to receive structured electronic invoices compliant with EN 16931 standards.

  • Suppliers are still allowed to issue (1) paper invoices. For (2) invoices in unstructured formats (e.g., PDF) and (3) non-EN-compliant EDI invoices, the buyer's consent is necessary. However, all these alternative formats are subject to gradual phasing out.

January 1, 2027: Phase 1 of the gradual phasing out of non-EN-compliant invoices.

  • Businesses with a turnover of more than EUR 800,000 in the previous year are no longer allowed to issue invoices (1) on paper or (2) in unstructured electronic formats, even with the buyer’s consent.

January 1, 2028: Phase 2 of the gradual phasing out of non-EN-compliant invoices.

  • All remaining businesses can no longer issue invoices (1) on paper or (2) in unstructured electronic formats, even with the buyer’s consent.

  • EDI e-invoices not compliant with EN 16931 will no longer be allowed.

Summary

Starting January 1, 2025, EN-compliant e-invoices will become the standard in Germany. The transition includes a gradual phase-out of paper invoices and non-EN-compliant electronic formats by 2028. This move aims to streamline business transactions and ensure compliance with European standards.