Unsurprisingly, proposed e-invoicing regulations sparked an intense debate among public and private entities in Germany. Current discussions are believed to be key for shaping the final provisions of the reform.
The process is at a stage at which key Federal Council (Bundesrat) committees (for internal affairs; urban development, housing and spatial planning) have given their recommendations to the main chamber. These will have to be worked through before the Bundesrat accepts the bill into law.
The list of opinions by the committees is quite extensive:
- The Federal Council maintains that costs associated with the reform should be proportional to its projected purposes. This pertains especially to issues of assuring compatibility of legacy invoice formats with newly proposed EN 16931.
- The Council advocates for postponing general e-invoicing introduction until 2027 due to German companies’ insufficient state of readiness for digital operations transformation.
- It is also believed that the currently assumed grace period for legacy invoice formats usage (from 2025 to 2027) will be ineffective, as it would require the consent of the recipient. Practically, it would mean the obligation would de facto come into force as early as 2025.
- Lastly, the committees criticized the lack of information about the level of CEN standard conformity necessary for legacy formats to be used during the aforementioned period.
In conclusion, the intensive legislative work around German e-invoicing exemplifies the nation's commitment to introducing a robust, nationwide system. With such progress, we can expect detailed requirements to be published sooner rather than later.