Current Status of B2B E-Invoicing in Germany (2025 Update)

Current Status Of B2B E-Invoicing In Germany

Germany prepares for mandatory B2B e-invoicing under the Wachstumschancengesetz, a growth and tax simplification law. Starting January 2027, companies with turnover exceeding €800,000 are obligated, while smaller enterprises join in January 2028. All businesses must be able to receive e-invoices by January 2025. Aligned with the EU’s ViDA plan, Germany will adopt the EN 16931 standard, without requiring data sharing with tax authorities. Unlike B2B, B2G e-invoicing remains decentralized, complicating nationwide implementation.

Updates on E-invoicing in Germany

The German Ministry of Finance (BMF) has published an updated guidance on B2B e-invoicing with the following main points:>

• Definition of e-invoices: Only invoices in formats such as XRechnung, ZUGFeRD, or conforming to the European standard EN 16931 constitute e-invoices. All other formats are considered “other invoices.”
• Mandatory acceptance: As of 2025 January, recipients of invoices are required to accept valid e-invoices and cannot reject them.
• Electronic archiving: Organized e-invoices have to be archived in their original form and be subject to unalterability rules. EDICOMLta’s storage solution meets the German GoBD requirements, ensuring document integrity and traceability.
• Corrective invoices: Corrections must be issued using the same structured format as the original invoice; manual or non-electronic changes are not allowed.
• Future reporting: The government is exploring the option of introducing a national portal for submitting specific invoice data electronically.

Germany's B2B E-Invoicing Rollout Timeline and formats

The German Ministry of Finance (BMF) has provided a step-by-step plan for B2B e-invoicing, setting standards for reception, issuance, and accepted formats:

From January 1, 2025

• All businesses must be able to receive e-invoices.
• Issuing e-invoices is voluntary.
• There will be no centralized national platform for e-invoicing.

Accepted Formats:

• Paper invoices
• E-invoices that follow EN 16931, like those in the national ZUGFeRD and XRechnung formats
• Other forms like e.g., EDIFACT and XML

2027, January 1

• Beginning on January 1, 2027, companies with yearly sales of over €800,000 will have to submit electronic invoices.

Accepted Formats:

• Paper: only allowed under specific conditions-
• E-invoices in accordance with EN 16931, such as ZUGFeRD and XRechnung Other (e.g., XML, EDIFACT).

From January 1, 2028

• For business-to-business transactions, all companies are required to send electronic invoices.

Accepted Formats:

• EN 16931-compliant electronic invoices like XRechnung and ZUGFeRD
• Other formats such as (XML, EDIFACT, etc.) only if fully compatible with EN 16931

Key Milestones in the Development of Germany’s B2B E-Invoicing Mandate

2021

The coalition parties started considering implementing an electronic reporting system based on e-invoicing.

November 2022

The federal government formally requested that the EU repeal Articles 218 and 232 of the e-invoicing directive.  These had insisted on advance consent from suppliers prior to electronic invoicing, which held back adoption.

April of 2023

On the agenda was a proposal from Germany's Federal Ministry of Finance (BMF) to mandate electronic invoicing between businesses. On April 17, 2023, the subject was opened to public comment.

June 2023

The European Commission suggested to the Council that it grant an interim exemption in response to Germany's request. This would allow the B2B e-invoice requirement to be implemented from January 1, 2025, until December 31, 2027, or until the ViDA goes into effect.

July 2023

The first draft of the Growth Opportunities Act, or Wachstumschancengesetz, was released by the BMF.  

Key features included:

• Limitation of the e-invoicing requirement to national B2B transactions.
• Definition of e-invoices within the CEN 16931 standard.
• Phased reduction of paper invoicing.

August 2023

A revised version of the Wachstumschancengesetz established an interim provision for applying EDI forms as a transition measure.

2 October, 2023

The BMF published an initial schedule for applying B2B e-invoicing standards.

20 October, 2023

The German Bundestag requested a two-year extension of the mandate to accept electronic invoices in its parliamentary response.

December 2023

The Bundestag already had an objective of having the Growth Opportunities Act passed by December 15. The Bundesrat, though, vetoed the bill passed on December 4, blocking the two-year grace period in mandating the use of e-invoicing.

February 2024

The bill was referred to mediation committee in order to iron out differences between Bundesrat and Bundestag. A compromise was agreed upon and passed by Bundestag on February 23.

22 March, 2024

The Growthschancengesetz, which was formally passed by the Bundesrat, confirmed that B2B e-invoicing would be required in Germany.

B2G E-Invoicing in Germany

From April 18, 2020, all German federal states have to accept e-invoices under EU Directive 2014/55/EU. Each state adopts its own rules for formats, communication systems, and portals but must all enable Peppol access.

Rhineland-Palatinate and Hesse will respectively compel the suppliers to provide e-invoices from January and April 2024.

Cross-Border E-Invoicing Simplified: Factur-X and ZUGFeRD Formats

Since 2015, Germany’s FeRD and France’s FNFE-MPE have jointly developed a unified e-invoicing standard to streamline invoice exchange across borders, particularly benefiting SMEs.

Factur-X is one of France's mandatory format through its e-invoicing overhaul from voluntary 2025 onwards.

One of the standardized formats under the new standard for B2B e-invoicing starting in 2025 is ZUGFeRD from Germany.

In accordance with European standard EN 16931, the harmonized release Factur-X 1.0.06 / ZUGFeRD 2.2 became available in March 2022. Factur-X 1.0.07 and ZUGFeRD 2.3 are now functionally compatible releases with multilingual documentation available in French, German, and English.  The enhancements extend the EXTENDED profile so it can cover sophisticated business cases with fully structured invoice information.

The formats also support country-specific profiles, including XRechnung for Germany and EXTENDED CTC-FR for France.

Conclusion

Germany's B2B e-invoicing as mandatory is a significant move towards tax reporting digitalization, business efficiency, and synchronizing with wider EU initiatives such as ViDA. With plans for implementation, adopted standards like XRechnung and ZUGFeRD, and endorsement of cross-border standards like Factur-X, all businesses should start preparing now. Adding familiarity with technical requirements, awareness of legal updates, and pre-installment of compliant systems will facilitate the process and ensure future compliance with the changing digital invoicing environment.