The Haufe editorial team writes "In Germany, electronic invoices are to be mandatory in the B2B sector in future. Corresponding VAT regulations are contained in the Growth Opportunities Act, which was passed by the Bundestag on 17.11.2023, but was referred to the Mediation Committee by the Bundesrat on 24.11.2023."



What is an electronic invoice?

An electronic invoice (Section 14 para. 1 sentence 3 UStG-E) is an invoice that is issued, transmitted and received in a structured electronic format and enables electronic processing. The structured electronic format must comply with the European standard for electronic invoicing and the list of corresponding syntaxes in accordance with Directive 2014/55/EU (and therefore the CEN standard EN 16931).



The format requirements are met, for example, by XRechnung, which is already used in public procurement, among other things, or the hybrid ZUGFeRD format (combination of PDF document and XML file). The BMF expressly confirmed this in its letter of 2.10.2023 to the associations (for ZUGFeRD only from version 2.0.1). However, other invoice formats that were not explicitly mentioned in the letter can also generally meet the requirements.



Important: A PDF invoice sent by email will therefore no longer be considered an electronic invoice from 2025!



When does the e-invoice obligation apply?

The basic obligation to issue invoices electronically will apply from 1.1.2025. However, in view of the expected high implementation costs for companies, the legislator has provided for transitional regulations (Section 27 (39) UStG-E) for the years 2025 to 2027.



Until the end of 2026...

paper invoices may continue to be sent for B2B transactions carried out in 2025 and 2026. Electronic invoices that do not comply with the new format will also remain permissible during this period, although (as before) the consent of the invoice recipient is required (sec. 27 para. 39 no. 1 UStG-E).





Source: Haufe-Lexware GmbH & Co KG