Introduction
Important changes to business-to-business (B2B) invoicing take effect on 1 January 2025. They affect every business in Germany, from major corporations to freelancers. From 1 January 2025, all businesses must be able to receive electronic invoices. From 1 January 2028 at the latest, only electronic invoices may be exchanged between businesses.
The introduction of electronic invoicing in Germany prepares the way for an electronic VAT reporting system intended to replace the current advance VAT return.
Exceptions
Under the new rules, invoices below EUR 250, travel tickets and certain VAT-exempt supplies are exempt from the obligation to send electronic invoices.
Format
Electronic invoices must comply with EN 16931 and use formats such as XRechnung or ZUGFeRD. Other electronic formats are also permitted if they are interoperable with EN 16931.
Transitional periods
Until 31 December 2026, paper or PDF invoices and other structured formats such as iDOC or in-house formats remain permitted, but only with the recipient’s consent. From 1 January 2025, recipient consent is still required for electronic formats unless the invoice is issued in a permitted format. Receiving invoices in those formats is mandatory.
Conclusion
The new rules aim to standardise and simplify electronic invoicing processes. Businesses should prepare early to meet the requirements.
Andreas Pelekies
Managing Director of valitool GmbH, co-founder of FeRD and co-author of EN 16931. The ZUGFeRD format was developed under his technical leadership.
