Germany plans to introduce B2B e-invoicing by 2025

Germany plans to introduce mandate B2B e-invoicing by 2025, according to a draft proposal released on 17 April 2023. This proposal is a discussion paper sent to the main German business stakeholders.

According to the information contained in the Government’ draft proposal:

• German e-invoicing would aim to cover domestic B2B transactions.
• German B2B e-invoicing would be in line with the European standard for electronic invoicing 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 changes its definition in the VAT Directive to refer exclusively to structured electronic invoices. This means that a PDF sent over email may no longer be considered an e-invoice.
• Electronic invoicing will be the default system for the issuance of invoices. The issuance of e-invoices will not depend on the acceptance of the recipient. 
• The use of paper invoices will only be possible in situations where Member States authorize them and will never be applicable to intra-Community transactions.
• The invoice standard format proposed is European e-invoice standard CEN 16931.
• Also, the content of invoices (semantic) will be extended according to the Commission’s proposal to include: i) an identifier of the bank account in which the payment for the invoice will be credited, ii) the agreed dates and amount of each payment related to a concrete transaction, and, iii) in the case of an invoice that amends the initial invoice, the identification of that initial invoice.

Businesses have until 8 May to submit their feedback to the BMF.