E-Invoicing in Germany: Latest Changes and Additions


September 1, 2023

A previous blog post published through our German region noted that Germany plans to make electronic invoicing (e-invoicing) mandatory for business-to-business (B2B) transactions. This implementation of e-invoicing in Germany will commence on January 1, 2025. While the plan remains unchanged, the German ministry has put forth a series of proposals for amendments to the new e-invoicing law and its process. More about the latest recommendations for electronic invoicing and its implementation is presented in this blog post below.

Changes to E-Invoicing in Germany

Consent is no longer required for B2B transactions

Currently, obtaining the buyer’s consent is necessary for sending an electronic invoice. The proposed changes imply that invoices exchanged between taxable companies in Germany must be electronic. As a result, businesses will no longer need the buyer’s consent to send an electronic invoice.

The new definition of electronic invoice

A precise description of what constitutes an electronic invoice is introduced as part of the new legislative proposal. An electronic invoice is defined as one that is not only created electronically but also transmitted and received electronically. An integral aspect of this definition is that the invoice must be capable of electronic processing, which means it can be integrated into automated processes and systems.

Moreover, an e-invoice must adhere to the standards set by the European Committee for Standardization (CEN). This standard is identified as EN 16931, a European standard that ensures uniformity and cross-system compatibility of electronic invoices across different countries.

Dates and Deadlines

As previously mentioned, the implementation of mandatory e-invoicing in Germany will commence on January 1, 2025. However, there will be a transition period to allow German businesses time to adapt their processes to the new rules and requirements.

Paper invoices will be accepted until the end of 2025. Additionally, electronic invoices that do not meet the CEN standard could be issued with the buyer’s permission. With the new changes concerning the issuance of electronic invoices, businesses can send e-invoices that align with the CEN standard without requiring the buyer’s consent.

Electronic invoices do not need to comply with the CEN standard until the end of 2027. However, this applies only if the two companies engaged in a transaction mutually agree. In such cases, they can utilize electronic data interchange (EDI) to send invoices that do not conform to the CEN standard.

This legislative proposal doesn’t introduce new details about Germany’s plans to implement an electronic reporting system for B2B invoices, but it is mentioned that specifics will be provided later. You can subscribe to our newsletter to ensure you receive the latest updates directly via email.

TrueCommerce is also hosting a webinar on this topic where our experts will delve into the details and give you the opportunity to ask questions. Register for the webinar on Thursday, September 21, at 1:00 PM CET (Central European Time) to gain firsthand insights and practical tips for maintaining accurate and seamless tax compliance in Europe.

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