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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. Furthermore, until the end of 2027, paper invoices may still be submitted for B2B transactions carried out in 2027 if the issuing company had a maximum turnover of €800,000 in the previous year (2026).
Electronic invoices that do not comply with the new format (such as PDF files) will also remain permissible during the aforementioned periods if the recipient agrees to this format.
Important: Even if you are not yet required to send e-invoices due to the exemptions, you are still obliged to be able to receive and read them! There are special software solutions available for this purpose, many of which are even free of charge.
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"
- Website of the Federal Ministry of Finance about E-Invoices (FAQ)
Tip
Do you have basic questions about issuing invoices correctly? Check out our article, "How to Create a Correct Invoice?".
