German Finance Ministry’s New Draft on Mandatory B2B E-Invoicing and Implementation Clarifications

• The German Federal Ministry of Finance released a draft letter on mandatory B2B e-invoicing.
• Since January 2025, only invoices meeting CEN standard EN 16931 are valid for domestic transactions in Germany.
• Transitional regulations are in place until December 2027.
• The new regulations will be included in the German Administrative VAT Guidelines.
• Additional details and practical guidance are expected, but the e-invoice reporting system is not addressed.
• Associations have until August 2025 to provide feedback.
• Clarifications aim to aid implementation, but some issues remain unresolved.
• B2B supplies by small businesses are exempt from e-invoicing; reverse charge and other schemes are not.
• Clarification on exempt supplies with VAT options is missing.
• Supplies involving foreign parts of German taxable persons are treated as domestic.
• Construction industry clarification: invoice correction is not needed for remuneration discrepancies, but required for changes in scope or content.
• E-invoice authenticity, integrity, and legibility must be ensured.
• Storing the structured part of an e-invoice in its original form is sufficient.
• Non-compliant storage systems do not breach VAT regulations.
• Mandatory invoice information is part of the EN 16931 standard core data model.

Source: kmlz.de

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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