German e-invoicing mandate updates

Electronic Invoice Forum Germany (FeRD) announced on May 7, 2025, an update to ZUGFeRD to coincide with France’s Factur-X1.07 update. ZUGFeRD 2.3 includes updates to Code Lists to align with requirements set out in EN16931, plus editorial and schematron corrections.

The first phase of Germany’s business-to-business (B2B) e-invoicing mandate comes into effect, requiring German businesses to be able to receive e-invoices for B2B transactions. This requirement applies to all businesses, regardless of size or annual turnover. Acceptable e-invoicing formats must be compatible with standards outlined in European Norm (EN) 16931, such as XRechnung and ZUGFeRD. There are a small number of exemptions, including invoices under €250 and tickets for passenger transport. As part of Germany’s phased approach to implementing e-invoicing, the requirement to issue e-invoices for businesses of all sizes and turnover will be in place by January, 2028.

The Federal Ministry of Finance (BMF) publishes the final version of guidance for implementing Germany’s B2B e-invoicing mandate, being introduced from January 1, 2025. The guidance includes details on e-invoicing requirements and accepted formats, such as XRechnung and ZUGFeRD.

Germany will take a soft approach to implementing e-invoicing, with transition periods and flexibility for smaller businesses in particular. German authorities clarify that while all businesses must be capable of receiving e-invoices by January 2025, issuing them remains optional until 2027. Germany also clarifies that from January 2025, an e-invoice will be defined as “an invoice that is issued, transmitted and received in a structured electronic format and enables electronic processing” — such as XRechnung. Standard PDFs created, transmitted, and received electronically will not be considered e-invoices.

The Growth Opportunities Act introduces various tax measures, including a mandate for B2B e-invoicing. Germany outlines plans to implement e-invoicing in phases, starting with a mandate to receive structured e-invoices from January, 2025, followed by a broader requirement to issue structured e-invoices from January 2028.

The German government formally asks the European Commission for permission to mandate e-invoicing, beginning with B2B transactions. The government believes that e-invoicing will “...significantly reduce the susceptibility to fraud of our VAT system and modernise and at the same time reduce the bureaucracy of the interface between the administration and the businesses.”

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