European mandates

Historic approval: German Bundesrat greenlights B2B e-Invoicing mandate

On 22 March 2022, the German Bundesrat approved the proposed B2B e-invoicing mandate, marking a major leap towards digital transformation in one of the world’s largest economies. The rollout begins on 1 January 2025 (it is mandatory to accept structured e-invoice compliance with EN16931), with full implementation foreseen for 1 January 2028.

Germany’s Bundesrat (Federal Council) consented to the Growth Opportunities Act (Wachstumschancegesetz), which includes a mandatory domestic B2B invoice phased in between 2025 and 2028. The Bundestag already approved this wide-ranging economic stimulus bill. The bill can now complete the legislative process with the signatures of the Chancellor and President and then be gazetted.

Importantly, the German e-invoicing regime does not (yet!) include government pre-clearance or post-issuance digital reporting. It only mandates structured e-invoicing between businesses. This will probably change in 2030 with the EU VAT in the Digital Age digital reporting requirements. The existing German standards XRechnung and ZUGFeRD will continue.

Key takeaways

  • Phased Implementation: The rollout begins on 1 January 2025, with businesses mandated to accept structured e-invoices compliant with EN16931. Full implementation is expected by 1 January 2028.
  • Legislative Process: The Growth Opportunities Act (Wachstumschancegesetz), containing the B2B e-invoicing mandate, undergoes approval from the Bundesrat and Bundestag, paving the way for its enactment.
  • Continued Standardization: Existing German e-invoicing standards, such as XRechnung & ZUGFeRD, will continue alongside the new mandate, ensuring continuity in invoicing practices.
  • Future Implications: While government pre-clearance or post-issuance digital reporting are not currently part of the mandate, changes may occur with the EU VAT in the Digital Age digital reporting requirements anticipated around 2030.

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