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With the Growth Opportunities Act, the regulations for issuing invoices under Section 14 of the German VAT Act (UStG) have been revised for transactions conducted after December 31, 2024. The core of the new regulation is the mandatory use of e-invoices for transactions between domestic businesses.
Since April 1, 2023, crafts and other companies working with public authorities in Mecklenburg-Vorpommern have already been required to submit invoices electronically. Now, e-invoices are becoming mandatory for everyone.
What defines an e-invoice?
An e-invoice is specifically one that is created, sent, and received in a structured electronic format, allowing for automatic processing. Therefore, a PDF-format invoice is not considered an e-invoice.
E-invoices provide quick and automated responses without requiring manual data entry from stacks of paper into bookkeeping systems. They are an essential component in optimizing digital office processes and relieving accounting departments of routine tasks. Furthermore, e-invoices can be delivered and archived both more securely and with fewer resources.
What requirements must be met?
The structured electronic format of an e-invoice:
- must either comply with the European standard for electronic invoicing as per Directive 2014/55/EU, or
- may be agreed upon between the invoicer and the invoice recipient. However, the format used must allow the correct and complete extraction of the information required under Section 14 UStG into a format that either meets EN 16931 or is interoperable with it.
What are the exceptions and transition arrangements?
Invoices for services exempt from VAT under Section 4 Numbers 8 to 29 UStG, invoices for small amounts up to 250 euros (§ 33 UStDV), and travel tickets (§ 34 UStDV) are exempt from the e-invoice requirement. Invoices to end consumers are not affected by the e-invoice mandate.
Additionally, the legislator has provided transitional arrangements for the years 2025 to 2027. Until the end of 2026, paper invoices may still be used for domestic B2B transactions conducted in 2025 and 2026. Electronic invoices that do not meet the new format requirements (such as PDF files) will also be permitted during this period.
Where can I find more information about e-invoices?
You can find more information, for example, here:
- Federal Ministry of Finance letter from October 15, 2024, clarifying open questions on implementing the e-invoice requirement from January 1, 2025
- Website of the Federal Ministry of the Interior (BMI), "What is an e-invoice?", offering comprehensive explanations
- Fact sheet by the digital association Bitkom, "10 Key Points for Electronic Invoices"
Tip
Do you have basic questions about issuing invoices correctly? Check out our article, "How to Create a Correct Invoice?".
