Germany is pressing forward with its phased B2B e-invoicing mandate, which began on January 1, 2025, requiring all VAT-registered businesses to receive structured e-invoices. As part of this broader reform, suppliers will be required to issue e-invoices starting in 2027, with strict technical and legal conditions set out in line with EU standards.
On June 25, 2025, the Federal Ministry of Finance (BMF) published a second draft letter amending the VAT Implementation Decree (UStAE). The document introduces further clarifications ahead of full implementation, including:
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Invalid if incorrect: Format or content errors make e-invoices non-compliant.
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Same format for corrections: Invoice corrections must match the original format.
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Validation tools advised: To ensure compliance with EN 16931.
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Exemptions: Small amounts, tickets, and small businesses are excluded.
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Consent rules: B2C e-invoices require recipient approval.
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Archiving: XML must be stored for 8 years in original form.
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Input VAT rules: Only fully compliant e-invoices are eligible.
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Special cases: Includes insolvency, joint ownership, and notarial rules.
The draft is open for feedback via industry associations and will be finalized by the end of 2025.
