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Germany Regulatory Updates-2 October 2024

Hatice Ozcan

Oct 17, 2024

BMF publishes new “letter” on mandatory B2B e-invoicing being phased in 2025 – 2028


Germany’s Ministry of Finance (BMF) on 15 October 2024 issued a final letter (update of June draft) detailing the scope and regulations for the upcoming launch of mandatory B2B  e-invoicing for resident businesses. The phased implementation will take place from January 1, 2025, through January 1, 2028. Here are the main points:


Key Aspects of the B2B E-Invoicing Mandate


  • Phased Implementation:

    • January 1, 2025: All businesses must be capable of receiving structured e-invoices that comply with the EN16931 standard. Buyer consent will no longer be necessary for receiving e-invoices.

    • January 1, 2027: Businesses with an annual turnover exceeding €800,000 must issue only EN16931-compliant e-invoices.

    • January 1, 2028: The mandate will cover all businesses, requiring them to both issue and receive e-invoices exclusively.


  • Scope and Formats:

    E-invoices must comply with the EN16931 standard or an agreed-upon alternative format that allows proper VAT data extraction. Accepted formats include XRechnungZUGFeRD, and other EN16931-compatible formats.


  • Transmission and Compliance:

    E-invoices can be sent via email, electronic interfaces, or portals. Physical media (e.g., USB sticks) are not allowed. Recipients are responsible for ensuring compliance, and non-compliant invoices, such as PDFs or paper, will not be valid for tax deductions.


  • Exemptions:

    Exemptions apply to tax-free services, invoices under €250, and small-value invoices, which can continue to be issued as paper invoices until December 31, 2026.


  • Corrections and Documentation:

    Any corrections to e-invoices must also be submitted electronically.

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