On 25th of July 2023, the European Commission issued a derogation decision allowing Germany to proceed with implementation of a federal B2B e-invoicing mandate. The decision, in accordance with Germany’s original application, allows the mandate to begin on January 1st 2025. However, this date is expected to shift, as the German Ministry of Finance has proposed postponing the mandate for a year, until January 1st 2026.
In accordance with the EC’s decision, the mandate will only apply to domestic transactions by invoice issuing and receiving entities established in Germany. This means foreign bodies and international transactions will be exempt from the e-invoicing obligation.
The new invoicing system and specified e-invoice formats will be made the default procedure. However, current dematerialized invoice formats will be allowed to be issued until full implementation of the mandate on January 1st 2028.
This will not be the country’s first implementation of an e-invoicing mandate. In 2020, Germany introduced obligatory e-invoicing for B2G transactions at the federal level, with numerous federal states voluntarily adopting it.