Enforced Electronic Invoicing in Germany Starting in 2025
German Companies Prepare for Mandatory Electronic Invoicing by 2028
German companies are gearing up for a significant change in their invoicing practices, as a new regulation mandates the use of structured electronic invoicing (e-invoicing) for all B2B transactions starting from January 1, 2028. The transition will be phased in over three steps, with companies required to be ready to receive e-invoices from January 1, 2025, and large companies with an annual turnover of over €800,000 starting to issue e-invoices from January 1, 2027.
Preparing to Receive E-Invoices
From January 1, 2025, all businesses resident or established in Germany must have the technical capability to receive and process structured electronic invoices for domestic B2B transactions. This means companies must accept e-invoices sent in the prescribed formats without requiring prior consent from the invoice recipient.
Issuing E-Invoices in Compliant Formats
For issuing electronic invoices, companies must use structured e-invoice formats compliant with the European standard EN16931. The formats specifically endorsed include XRechnung and ZUGFeRD, which incorporate all mandatory invoice data fields in a machine-readable XML-based format. E-invoices must include all required elements such as supplier and customer data, net amount, VAT amount, service date, and clearly marked credit notes when applicable.
Validated and Standardized Data
The e-invoices must pass validation checks against XML and Schematron rules to ensure full compliance with the EN16931 standards and German VAT requirements. This prevents the invoices from being rejected or considered invalid for VAT deduction purposes. Incorrect or non-compliant e-invoices cannot be simply corrected by attaching unstructured documents like PDFs. Validation before sending or accepting invoices is highly recommended.
Transmission Methods and Channels
Although the regulatory texts do not mandate a single transmission channel, many German companies use the PEPPOL (Pan-European Public Procurement Online) network to send and receive e-invoices securely and interoperably across borders and systems. PEPPOL serves as a standardized delivery network widely accepted for e-invoicing, facilitating compliance with data format and security standards. Companies can route e-invoices via PEPPOL, or use other certified service providers and electronic platforms compatible with EN16931 and German rules.
Storage and Record-Keeping
E-invoices must be stored securely and in a way that guarantees authenticity, integrity, and legibility for at least 8 years (10 years for general accounting documents). This is critical for audit and tax purposes.
Adapting to Local Regulations
For Italian companies and large groups with offices in Germany, Intesa has developed a service to help them adapt to the local electronic invoicing regulations. Intesa's solution accommodates future electronic invoicing obligations in other European countries and provides compliant document archiving for German records.
Phased Implementation Timeline
- From January 1, 2025: All companies must receive e-invoices.
- From January 1, 2027: Companies with annual turnover over €800,000 must also start issuing e-invoices.
- From January 1, 2028: Mandatory issuance of e-invoices for all domestic B2B transactions.
Secure Transmission and Compliance
All electronic invoices must comply with EN 16931 standards. The transmission of electronic invoices will occur through secure channels monitored by tax authorities, such as local public administration portals. Hybrid invoices (e.g., ZUGFeRD) are accepted, as long as both structured and unstructured formats are combined into a single file.
Non-compliance risks losing input VAT deduction rights and possible legal penalties beginning in 2027. Companies should manage the exchange of "domestic" electronic invoices with German partners starting in January 2025. By relying on Intesa, companies will be prepared for the introduction of similar requirements in other European countries.
1. As business operations become more reliant on technology, finance departments in German companies must ensure their systems can handle structured electronic invoicing (e-invoicing) compliant with European standard EN16931, in preparation for the mandatory phased implementation by 2028.
2. To maintain a competitive edge in the business landscape, companies should integrate secure transmission methods for e-invoices, such as the PEPPOL network, to comply with the new regulation and be ready to exchange compliant digital invoices with both local and international partners when the mandate takes effect in 2028.
