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Germany sets timeline for countrywide e-invoicing mandate

Tuesday 26th March, 2024

The Bundesrat, Germany's legislative body representing the Federal States has approved the Growth Opportunities Act mandating B2B e-invoicing.

Germany has been in a long process of legislating an e-invoicing obligation for business transactions. With this approval, the introduction of mandatory B2B e-invoicing is officially starting from 1 January 2025.

Below are the implementation timelines.

1 January 2025 - EN-compliant e-invoice becomes the default in Germany.
• Businesses must be prepared to receive structured electronic invoices compliant with EN 16931 standards;
• The supplier is still allowed to issue (1) paper invoices. For (2) invoices in unstructured formats (e.g. PDF) and
  (3) non-EN-compliant EDI invoices, buyer's consent is necessary. 

1 January 2027 - Phase 1 of a gradual phasing out of non-EN-compliant invoices
• Businesses with turnover > EUR 800 000 in the previous year are no longer allowed to issue invoices (1) on paper
  or (2) in unstructured electronic formats. 

1 January 2028 - Phase 2 in gradual phasing out of non-EN-compliant invoices
• All remaining businesses can no longer issue invoices (1) on paper or (2) in unstructured electronic formats.
• EDI e-invoices not compliant with EN16931 will no longer be allowed.

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