Update on mandatory e-invoicing in Germany for B2B domestic transactions

The German Federal Ministry of Finance (‘BMF’) plans to introduce B2B invoicing in Germany within the framework of the European Commission proposed “ViDA” (VAT in the Digital Age) and be compliant with the EN16931 European e-invoicing standard.

On 17th April 2023, the BMF sent a proposal regarding the introduction of B2B e-invoicing for domestic transactions in Germany to a selection of German large enterprises. Industry is asked to provide the BMF with their feedback regarding the implementation of this proposal by 8th May 2023.

It is expected that e-invoicing shall be introduced for domestic B2B supplies by 1st January 2025, where the supplier is established in Germany. From this time, paper and PDF invoices would no longer be acceptable. It is not yet clear whether fixed establishments of foreign companies, or non-established businesses could be impacted.

How this obligation will be introduced is also still unclear (for example, whether this would be rolled out in stages, based on the size of the enterprise). Potentially, small value invoices will not be covered by this mandate. Further exceptions could be possible.

When planning the implementation of this requirement, companies who will be impacted by the introduction of e-invoicing for B2B supplies in Germany should also consider the current proposal for the introduction of e-invoicing requirements expected to come into force on 1st January 2028 as a component of ViDA.