Guidance on Germany’s 2025 E-Invoicing Mandate Released

The German Ministry of Finance has published a draft letter offering further guidance on the forthcoming e-invoicing mandate. The main points covered are as follows:

While the existing requirements do not yet include e-reporting, this is expected to be introduced at a later stage. Also, by January 2025, businesses must be prepared to receive electronic invoices, with an email inbox being a sufficient method for compliance. However, other electronic transmission channels can also be used by mutual agreement.

The issuance of electronic invoices will become mandatory in phases between 2027 to 2028. These invoices must be in either a structured format, which complies with EN 16931 or allows for accurate and complete extraction according to this standard, or a hybrid format that includes both structured data and a human-readable PDF.

The e-invoicing requirement will apply to all domestic transactions, with exceptions for tax-free service invoices, invoices up to €250, and tickets. Only businesses based in Germany will be subject to e-invoicing requirements. Non-residents without a German office or residence are exempt.

Finally, businesses will only be able to claim input VAT deductions through electronic invoices once e-invoicing becomes mandatory.

‍