E-invoicing: New obligation from 2025

In principle, every entrepreneur based in Germany is subject to the e-invoicing obligation from 2025.

Every entrepreneur is required to be able to receive e-invoices starting on January 1, 2025.

The new regulation for mandatory e-invoice issuance applies to business relationships between two entrepreneurs based in Germany (B2B sector). Excluded are transactions in the end-customer sector (B2C sector) as well as small invoices up to 250 EUR gross and travel tickets.

The term "e-invoice" is redefined under the new legislation. Invoices are only considered e-invoices if they are in a structured electronic format and comply with the EN 16931 standard.

All other types of invoices that are sent electronically (e.g., PDF) or issued in paper form are considered "other invoices", which do not meet the e-invoice standard.

The Federal Ministry of Finance (BMF) has already clarified that the so-called XRechnung (XML format) and invoices in the ZUGFeRD 2.X format comply with the EN standard.

From January 1, 2025, entrepreneurs are required to receive e-invoices according to the new regulations. No exceptions are provided (e.g., for small businesses). Additionally, audit-proof document storage must be ensured.

The obligation to issue e-invoices also begins on January 1, 2025. However, until December 31, 2026, invoices can still be sent as paper invoices or other electronic invoices (e.g., PDF) during a transition period.

Starting January 1, 2027, this transition rule will only apply to businesses with a total revenue of up to 800,000 euros in the previous calendar year.

By January 1, 2028, the transition period will end for all companies. By then, all businesses in Germany must send B2B e-invoices.

No, the German regulation only applies to the B2B sector between entrepreneurs based in Germany. If you have business establishments or VAT registrations in other EU countries, you must check whether e-invoicing regulations are already in place in those countries.

The regulations for the mandatory use of e-invoices apply equally to invoices issued in the form of credit notes.

EDI invoices can be used until December 31, 2027. Starting on January 1, 2028, EDI invoices will only be allowed if they are in a format that complies with the EN 16931 standard.

Recurring invoices must be issued as e-invoices. It is sufficient if an e-invoice is issued for the first term, with the underlying contract attached as an appendix, or if it is clearly evident from the content that it is a recurring invoice.

Yes, supplementary information can be included in an attachment integrated into the e-invoice. For example, a rental contract can be attached to the e-invoice.

Yes, every entrepreneur is required to receive e-invoices. This obligation applies regardless of whether taxable or tax-exempt transactions are conducted. Additionally, for taxable transactions, there is an obligation to issue e-invoices. The aforementioned transitional rule also applies here.

There is no age exemption regarding the e-invoicing obligation. Both the requirement to be able to receive e-invoices and the obligation to issue e-invoices apply.

The structured electronic data set is identical. The ZUGFeRD format, as a hybrid format, allows for visualization.

The structured invoice data, and therefore the information in the XML file, is decisive and takes precedence over the visual PDF view.