The e-Bill law, enacted in April 2017, along with the September 2017 Regulation on e-Invoicing, requires all federal contracting authorities to receive and process electronic invoices regardless of the invoice amount. The e-Invoicel law sets specific implementation dates: by 27 November 2018, top federal authorities must be able to handle eInvoices, and by 27 November 2019, this requirement extends to all subordinate and sectorial federal authorities. As of 27 November 2020, issuing and processing eInvoices to all federal public contracting authorities became mandatory. All central public authorities and the state of Bremen must issue, process, and accept eInvoices in the XRechnung format.
The law pertains solely to federal regulations, including sectorial contractors and licensors. State or local authorities impacted by Directive 2014/55/EU need additional legislation from the federal states (Länder). At the federal state level (Länder), the Directive has been fully integrated into supplementary legislation. From 18 April 2020, authorities of the federated states are required to accept eInvoices.
On 23 March 2024, the Federal Ministry of Finance issued the Act to Strengthen Growth Opportunities, Investment and Innovation, as well as Tax Simplification and Tax Fairness (Growth Opportunities Act).
1.What is the implementation timeline for B2B transactions in Germany?
1 January 2025: Companies must be able to receive e-Invoices. The EN-compliant e-invoice becomes the standard practice in Germany, although it is not yet compulsory.
1 January 2027: It will be mandatory to issue e-Invoices for companies with an annual turnover exceeding 800,000 EUR.
1 January 2028: All companies must be able to issue B2B e-Invoices in EN-16931 complaint format.
2.Will it be possible to use paper invoices at the very beginning of the implementation?
Yes. Germany envisages a transitional phasing. The issuance of paper invoices will be transitionally allowed in 2025 and 2026. PDF and non-EN compliant EDI invoices will be subjected to the buyer’s consent. However in 2027, it will only be possible with conditions (companies with annual turnover lower than 800,000 EUR). Finally it will be obligatory for every company to send and receive invoices electronically.
3.What does EN-16931 Format Mean and What are Germany’s Complaint Formats ?
EN-16931 forms the foundation of the EU’s directive aimed at standardizing electronic invoicing for public procurement among its member states. As a key component of Directive 2014/55/EU, it provides a unified semantic data model for electronic invoices, ensuring that invoice content is interoperable and understandable across different systems. This standard supports the use of multiple syntaxes, such as UBL and UN/CEFACT CII, adhering to the semantic model to guarantee extensive compatibility and ease of use.
Germany has 3 formats aligning with the EN-16931 namely; XRechnung, ZUGFeRD and Peppol BIS 3.0.
4.Is there a specific distribution channel for the transmission of e-Invoices?
Requiring specific methods for exchanging invoices is a common approach in countries with established e-invoicing mandates. This often includes the creation of national or private platforms and exchange networks. These systems typically replace direct exchanges between suppliers and customers. In contrast, Germany does not prioritize enforcing a specific exchange channel, allowing German companies to select their preferred methods for invoice transmission. Although email exchange may seem like the simplest solution for now, Germany might come up with a more secure solution in the future.
5.Is there a digital reporting requirement in addition to e-Invoicing?
No. The Growth Opportunities Act does not involve a digital reporting mandate. However, under this new legislation, it is expected that Germany will aim to harmonize with the reporting requirements mandated by ViDA in the near future.
