Introduction of mandatory electronic invoicing from January 1, 2025

What is an e-invoice?

An e-invoice (short for electronic invoice) is an invoice that can be transmitted, received and processed electronically in a so-called structured electronic format.

PDF invoices are not invoices in this sense (although they are sent electronically); basically, an e-invoice is a data record that contains the usual mandatory information of a regular invoice, but is not (or no longer) readable by the human eye, but is read by a program. Any file format that complies with the European standard for electronic invoicing (EN-16931) can be used for this – XML, for example, is a common format. Hybrid formats, which still contain a human-readable part in addition to the machine-readable part, are also permitted.

All invoices that do not correspond to these formats will be considered other invoices (paper invoice, PDF, etc.) in the future.

A variety of programs can be found for creating and reading the new electronic invoice formats.

Who is obliged to issue e-invoices from January 1, 2025?

The new regulation applies in the so-called B2B area (business to business). It affects all companies (i.e. also self-employed persons and freelancers) that perform/realize a supply (delivery or service) that is taxable in Germany to another company if both are based in Germany.

The regulation does not apply to business relationships with private customers or end consumers. Here, the invoice recipient must give their explicit consent to receive an e-invoice.

Small businesses will not be obliged to invoice their services using an e-invoice in future. However, from January 1, 2025, they will be required to be able to receive, read and archive e-invoices. An email inbox is sufficient for receiving e-invoices, while free and paid programs are available for reading them out.

There is a transitional period until the end of 2026 for the introduction of e-invoicing.

Other

There are exceptions for very small invoices (up to EUR 250.00 gross).

Contracts also count as invoices – however, an e-invoice must be issued for the first partial service period and the underlying contract must be attached as an e-invoice. If the mandatory information changes, a new e-invoice must be issued.

Draft letter from the Federal Ministry of Finance