New information and timetable for the implementation of e-invoicing in Germany

A new law in Germany (“Wachstumschancengesetz”) is expected to be discussed in the parliament in December 2023. This law is part of the German government’s digitisation strategy.

Part of the law includes the requirement for invoices to be sent electronically between companies (B2B).

We know that:

• Paper invoices lose their priority and will eventually not be approved.

• Electronic invoice formats in Germany will follow the EN16931 standard.

• The change only applies to B2B invoices sent within the borders of Germany.

• It includes all companies located in Germany.

• CTC is not mentioned in the bill, but Germany is expected to follow the ViDA requirements for cross-border B2B invoices in 2028.

Timeline of the implementation:

Summer 2023: The draft was published and discussed with relevant stakeholders.

December 2023: The draft is expected to be considered in parliament.

1 January 2025: The priority of paper invoices will be removed and companies must be able to receive e-invoices.

January 1, 2026: It will be mandatory for companies with an annual turnover of more than 800,000 euros to send B2B e-invoices!

Invoices in EN format will become the standard.

1 January 2027: All companies must send and receive electronic B2B invoices.

1 January 2028: B2B e-invoices. Only in a format that complies with the EN 16931 standard. Expected compliance with ViDA.

Overview of sending and receiving invoices

*XRechnung and ZUGFeRD from V2.0 meet EN 16931 requirements. Other formats adapted to EN 16931 are also permitted.

Receipt of invoices 2025: All companies in Germany must be ready to receive e-invoices from 1 January 2025

Why is it important?

Companies that have subsidiaries in Germany will be affected by these requirements, and as early as 2026, paper invoices will only be allowed under certain conditions. It is therefore important that companies with companies in Germany decide how they will comply with these requirements.

Contact us today to discuss how we can help your business comply with the upcoming e-invoicing requirements in Germany. We are keeping up to date on the situation and will share as soon as we know more!