E-Invoicing in Germany: Complete guide

Germany plans to introduce B2B e-invoicing by 2026.


What is e-invoicing in Germany?

Germany plans to introduce a mandate to issue electronic invoices in B2B transactions.

An electronic invoice is an invoice that has been issued, transmitted, and received in a structured data format which allows for its automatic and electronic processing. A structured electronic invoice contains data from the supplier in a machine-readable format, that can be automatically imported into the buyer's system avoiding manual entering.

Mandating e-invoicing in Germany implies a legislative change in the current definition of an electronic invoice. According to the proposal, e-invoicing shall exclusively refer to a structured electronic invoice. This means that a PDF sent over email will no longer be considered an e-invoice.

Have a look at our e-invoicing overview. It includes the implementation status of the mandated use of electronic invoicing in Europe.

When will e-invoices in Germany become mandatory?

Following the latest updates, Germany plans to introduce mandate B2B e-invoicing by January 2027. An initial discussion paper proposed the introduction of e-invoicing in Germany by January 2025. However, during the subsequent discussions of the legislative proposal Growth Opportunities Act, the rollout in phases has been delayed: first to January 2026, and more recently, there is a new request for postponement to January 2027.

At the moment, the e-invoicing phased implementation schedule is the following (you should consider the possibility of an additional 1 year delay):

  • January 2026, for taxpayers with an annual turnover exceeding EUR 800,000
  • January 2027, an extension of the mandate to all German taxpayers.

An important milestone was reached by receiving the EU authorization to implement the mandate on B2B electronic invoicing by way of derogation of articles 218 and 232 of the EU VAT Directive. German B2B e-invoicing mandate is now a solid plan. 

Mandatory B2B e-invoicing in Germany

According to the information contained in the draft legislation, German e-invoicing would aim to cover all domestic B2B transactions. Transactions excluded from the mandate are intra-Community transactions and simplified invoices.

In principle, the B2B e-invoicing mandate will only impact German established businesses and fixed establishments of foreign companies.

German B2B e-invoicing will be in line with the European standard for electronic invoicing (CEN 16931) and the list of corresponding syntaxes according to Directive 2014/55/EU of April 16, 2014. This is the format proposed in ViDA.

The German proposal implies early compliance with ViDA regulations concerning electronic invoicing: electronic invoicing will be the default system for the issuance of invoices and the issuance of e-invoices will not depend on the acceptance of the recipient.

Additionally, mandatory B2G e-invoicing has already been in place since 2020 in Germany, although the system is decentralized in the German federal states.

Have a look at our overview of e-invoicing in Europe. It includes the current implementation status of e-invoicing mandates across Europe.

Benefits of electronic invoicing for companies

E-invoicing provides companies with faster and simpler document processing and, consequently, faster payment, saving on paper and shipment costs, higher efficiency and automation of internal processes, as well as real-time invoice information for business management purposes.

From the tax authorities’ perspective, mandating the use of electronic invoices has the clear advantage of reducing VAT fraud, particularly if it comes in hand with a CTC measure. 

Have a look at our article about electronic invoicing

How to submit German e-invoices

Based on the current draft legislation, there is no reference to the implementation of digital reporting requirements or DRR connected to the electronic invoice mandate, or the introduction of other CTCs.

There are areas requiring further definition in e-invoicing implementation in Germany. The authorities want to develop their project in parallel with the Pillar 1 of the ViDA proposal on e-invoicing and digital reporting requirements. Therefore, we shall wait for further developments on the platforms for exchange.

 


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