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German B2B Status and Recent Updates

Germany is implementing the Wachstumschancengesetz law for business growth, tax equity, and streamlined tax procedures. The B2B e-invoicing initiative was initially scheduled for full implementation by January 2025, but a phased approach has been proposed. By January 2025, all companies must be equipped to receive e-invoices. Germany plans to adopt the European e-invoicing standard EN 16931 without data sharing with tax authorities. However, Germany’s decentralized B2G e-invoicing system across federal states presents a significant hurdle in establishing a unified B2B billing system.

The milestones in the progression of B2B e-Invoicing in Germany include exploring an electronic reporting system in 2021, requesting the elimination of articles from the European Directive on e-invoicing, and implementing e-invoicing for B2B transactions. The BMF (The German Federal Ministry of Finance) has proposed a provisional implementation schedule for the B2B project, with mandatory e-invoice issuance by January 1, 2027, and all companies issuing B2B e-invoices by January 1, 2028.

The Bundestag has approved the Growth Opportunities Act, which brings notable alterations to electronic invoicing. The law awaits confirmation from the Bundesrat, set to convene on before at the end of March 2024. The proposed legislation outlines mandatory e-invoicing implementation from 2025 to 2028, gradually transitioning to structured e-invoices as the standard format. 

Regarding B2G e-Invoicing in Germany, federal states have been required to accept e-invoices since April 18, 2020. Peppol accessibility is a universal requirement across all states.

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