- Mandatory electronic invoicing for domestic transactions starts on 1 January 2025, with transitional provisions.
- A first BMF letter was published on 15 October 2024, and a draft of the second letter is now available.
- Final publication of the second BMF letter is scheduled for the fourth quarter of 2025.
A first BMF letter on the topic was published on 15 October 2024 (reference: https://www.bundesfinanzministerium.de/Content/DE/Downloads/BMF_Schreiben/Steuerarten/Umsatzsteuer/2024-10-15-einfuehrung-e-rechnung.html)
Click HERE for the second letter
Summary:
- Mandatory Introduction of Electronic Invoicing: Effective January 1, 2025, all transactions between domestic entrepreneurs will require the use of electronic invoices (e-invoices). The document outlines transitional provisions to facilitate this change, ensuring businesses can adapt to the new requirements without disruption.
- Amendments to VAT Application Decree: The document details various amendments to the VAT Application Decree (UStAE), specifying changes to definitions and requirements for invoices. Key points include:
- Classification of Invoices: As of January 1, 2025, all paper invoices and electronic formats that do not comply with specific structured electronic requirements will be classified as “other invoices.”
- E-Invoice Requirements: E-invoices must be issued in structured electronic formats that comply with the European standards (EN 16931). The document emphasizes that e-invoices must enable electronic processing and contain all necessary VAT information.
- Exceptions and Transitional Provisions: Specific exceptions are noted for small invoices (under €250), invoices from small businesses, and transportation tickets. These can still be issued as standard invoices with the recipient’s consent. The document clarifies that consent for electronic formats can be implicit and does not require formal documentation.
- Technical Specifications: The document provides comprehensive guidelines on acceptable e-invoice formats, including structured and hybrid formats, and outlines the technical requirements for ensuring the authenticity, integrity, and readability of invoices. It emphasizes that structured data must be extractable for compliance with VAT regulations.
- Record Keeping and Compliance: Businesses must maintain electronic invoices in their original form for at least eight years, ensuring that the structured part remains intact. The document outlines the responsibilities of both invoice issuers and recipients in ensuring compliance with e-invoicing regulations.
- Implementation Timeline: The final publication of the revised VAT Application Decree is expected in the fourth quarter of 2025, following a draft sent to associations for feedback in June 2025. The document indicates that the principles outlined apply to all transactions executed after December 31, 2024, while previous transactions will follow the existing regulations as of that date.
- Publication and Access: The document concludes with information on its publication in the Federal Tax Gazette and its availability for download on the Federal Ministry of Finance’s website, allowing businesses and stakeholders to access the updated regulations and guidelines.
Source BMF
Other sources
See also
Briefing document & Podcast: Germany E-Invoicing B2B Mandate, Timeline and Compliance – VATupdate
- See also
- Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
