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German B2B e-invoicing 2025-28 draft implementing regulations

BMF publishes draft high-level letter of regulations for implementation of e-invoicing

The German Ministry of Finance has published on 13 June 2024 a draft letter on the regulations for the upcoming mandate of B2B e-invoicing. This is now in circulation of general feedback until 11 July. It covers the first requirements, from 1 January 2025, the all resident taxpayers must be able to receive structured e-invoices for domestic B2B transactions.

The final publication of the BMF letter is for the beginning of the IV. Planned for the quarter of 2024. The letter covers:

  • Current legislative situation – the implementing Growth Opportunties Act
  • Types, formats and obligations to issue e-invoicing from 1 January 2025
    • New definition of a machine-readable structured e-invoice under END 16931 EU standard or agreed between counterparties that are secure. Some exemptions, including <€250 value.
    • Hybrid with XML, XStandard and ZUGFerd qualify
    • Attachments may be included to enable contract or similar commercial terms to be added
  • Electronic transmission of e-invoice, which may be email (but still structured (not PDF!), portals or service providers. No memory sticks or similar exchanges. So setting-up an email box to receive and store structured e-invoice would meet the Jan 2025 requirements.
  • Input VAT deduction considerations as only structured e-mail valid under above requirements.
  • Storage issues
  • Transitional arrangements see table below:

March 2024 Domestic B2B e-invoicing law gazetted following Bundesrat Federal Council consent

Germany has gazetted on 27 March  its Growth Opportunities Act (Wachstumschancegesetz), which includes mandatory domestic B2B invoice phased in between 2025 and 2028 (see diagram below).

Germany’s Bundesrat (Federal Council), consented on 22 March to the legislation, This wide ranging economic stimulus bill was already approved by the Bundestag.

Importantly, the German e-invoicing regime only governs the formats adopted for B2B domestic invoices. It does not (yet!) include government pre-clearance or post-issuance digital reporting. This will change probably 2030 with the EU VAT in the Digital Age digital reporting requirements for intra-community supplies. The existing German XRechnung & ZUGFeRD standards will continue provided they remain interoperable with the new rules.

Council of EU approves mandatory German e-invoicing

The request by the European Commission on behalf of Germany to introduce mandatory B2B domestic VAT e-invoicing was approved by the Council of the European Union on 25 July. This allows Germany to impose real-time e-invoicing which it is now proposing for 1 January 2025 to 2028.

The request was backed by the EU Commission in June (see below) to authorise Germany to derogate from the EU VAT Directive and its requirement for paper-based invoices. Germany will be permitted to impose e-invoices until the end of 2027 when there will be a further review.

Learn about VATCalc’s VAT e-invoicing product, which not only creates and submits e-invoices to global tax authorities, but is unique in providing full audit against local tax legislation. And since it is built on the same application as our VAT Filer, all of your sales or purchase e-invoices are fully reconciled to your VAT returns.

Germany’s application to the EC lasts until December 2027. However, the EU is proposing to remove this requirement to seek its approval to deviate from the EU VAT Directive on e-invoicing from 1 January 2024 (now delayed to probably January 2025. This is part of the ViDA reforms.

This proposal follows a 2022 commitment from the new coalition government to introduce a digital reporting regime to help tackle the VAT Gap.

Germany is to follow Italy, France, Poland and others by introducing mandatory electronic invoices. It has commenced plans by seeking permission from the European Commission to do so – under the EU Directive rules, businesses must first seek their suppliers’ permission to adopt e-invoicing.

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November 2021: Coalition new leaders confirm electronic invoice reporting system as soon as possible to fight VAT fraud; backing for EU definitive VAT system; import VAT reforms

The new German government coalition of the SPD, Free Democratic Party (FDP) and Green Party have now confirmed on 24 November 2021 plans to implement a country-wide live e-invoicing regime. It is envisaged that this will validate in real-time the creation of sales invoices by taxpayers, and then act as the forwarding channel for invoices to customers. This follows the Italian SdI model, with Continuous Transaction Controls (CTC)which in turn follows similar models adopted across South America and Asia Pacific.

If you want live updates on these changes, sign-up for our free regular global VAT/GST newsletter.

The new government has also restated its support for the proposed EU definitive VAT system, which aim to shift the EU VAT regime to a destination principle. Check VAT Calc’s global live VAT invoice transaction and e-invoice reporting tracker to see where else real-time submissions of invoices is being implemented. Our VAT Calculator can produce accurate invoice calculations and reporting globally.

The coalition has also committed to reform the import VAT rules to provide similar reverse charge relief as is common across the rest of the European Union.

Read more about German VAT in our national guide.

Germany B2G e-invoices

As per the requirements of the EU VAT Directive on e-invoicing, in April 2020, Germany mandated the acceptance of electronic invoices for Federal governmental transactions with the commercial sector, B2G.The format varies by state (Bundesland) as they adopt the legislation in their local laws. The states have the option of their own format (which should be PEPPOL compliant) or the recommended by Core Invoice User Specification (CIUS).

Europe e-invoicing and live reporting

Country Date Comments (click for details)
EU e-invoice proposals 2030-35 Digital reporting and e-invoicing harmonisation
Albania Jan 2021 Authorised e-invoice software and pre-clearance
Belgium Jan 2026 Phased introduction of B2B e-invoices
Bulgaria TBC Public consultation on pre-clearance model e-invoice
Croatia Jan 2026 B2B mandatory e-invoicing
Denmark 2024 Digital record keeping obligations
Estonia 2025 Suppliers must offer customers e-invoicing option
Finland Apr 2020 Customer option to require B2B e-invoices
France Sep 2026 E-invoicing and e-reporting for B2B and B2C
Germany 2025-28 B2B mandatory e-invoicing proposals
Greece 2025 e-invoicing based on exiting myDATA digital reporting
Hungary Jul 2018 RTIR live invoice reporting. No govt pre-clearance required
Jan 2024 eVAT pre-filled returns based on live invoice reporting
Italy Jan 2019 Micro businesses join SdI e-invoicing Jan 2024
Ireland TBC Public consultation underway
Latvia Jan 2026 B2B e-invoices based on PEPPOL
Lithuania TBC E-invoicing platform being scoped
Montenegro TBC B2B mandatory e-invoicing preparations
Netherlands No mandate planned Unlikely to adopt domestic reforms
Poland Feb 2026 B2B mandated e-invoicing
Portugal Jan 2024 Certified invoicing software for non-residents
Jan 2024 ATCUD digital invoice signature for non-residents
Romania Jul 2024 RO e-invoicing implementation
Russia TBC Extension of Traceability Model to B2B on hold
Serbia Jan 2023 B2B e-invoicing
Slovakia 2025 B2B and B2C e-invoice rollout
Slovenia 2025 ? e-SLOG B2B proposal stalled
Spain 1 Jul 2017 SII live invoice and book reporting
Spain 2 Jan 2026? Pre-clearance B2B e-invoices; supplement to SII
Spain 3 Jan 2026? Certified e-invoicing software VERI*FACTU
Sweden TBC PEPPOL based mandatory e-invoicing
Turkey Jan 2014 e-invoice e-Fatura and e-Arşiv
UK Apr 2022 MTD for VAT extended to 1.1million taxpayers


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