Germany Updates FAQs on Mandatory E-Invoicing: Key Clarifications and Transitional Provisions Explained

Clarified Scope of E-Invoicing Obligation: The updated FAQs specify that the mandatory e-invoicing rules apply to domestic B2B transactions where the supplier is established in Germany, allowing VAT-registered non-established entities to indicate their status on invoices for clarity.
Legal Hierarchy and Transitional Period: The guidance outlines that the VAT Act (UStG) and the Federal E-Invoicing Ordinance (ERechV) operate independently, with specific requirements for each. A transitional period allows some taxpayers until 2028 to issue invoices in paper or non-compliant formats while ensuring they can receive structured e-invoices by January 1, 2025.
Exemptions and Technical Compatibility: Small businesses are exempt from issuing structured e-invoices but must be able to receive them. Additionally, the ELSTER viewer now supports both XRechnung and ZUGFeRD formats, enhancing compatibility for structured invoice review, and the FAQs include updated legal references related to retention requirements.

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Germany Updates FAQs on Mandatory E-Invoicing: Key Clarifications and Transitional Provisions Explained

The German Ministry of Finance updated its e-invoicing FAQs on 5 November 2025.
Mandatory e-invoicing applies to businesses established in Germany; non-established VAT-registered entities can indicate their status to be exempt.
All taxpayers must be able to receive structured e-invoices from 1 January 2025, but issuing e-invoices in B2B transactions will be phased in gradually, possibly until 2028.
During the transitional period, paper or non-compliant invoices may still be used depending on business size and readiness.
Small businesses are exempt from issuing e-invoices but must be able to receive them in the required format.