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Germany – Mandatory E-Invoicing Requirements for B2B Transaction
The German Federal Ministry of Finance (BMF) has issued comprehensive guidance on the 15th of October 2025, clarifying technical requirements and compliance standards for the introductory mandatory electronic invoicing system.
This reform, part of the Growth Opportunities Act, fundamentally transforms B2B invoicing processes in Germany, aiming to digitalize business transactions, reduce fraud, and streamline tax administration.
Key Requirements
- Mandatory use of structured electronic invoices for domestic B2B transactions
- Compliance with EN 16931 technical standards
- Validation through approved applications
- Original format archiving requirements
- Electronic credit notes for corrections
Technical Specifications
The BMF guidance outlines specific requirements for:
- Format compliance and data extraction standards
- Business rule validation processes
- Readability requirements for EN 16931-compliant e-invoices
- Permitted distribution methods (EDI, email, or other approved channels)
- Archiving protocols in original structured format
Implementation Timeline
| Phase 1 (1st of January 2025 – 31st of December 2026) | • Voluntary adoption period • Alternative invoice types and paper invoices remain acceptable • Special provisions for businesses with turnover up to €800,000 |
| Phase 2 (1st of January 2027) | • Mandatory for all domestic B2B companies |
| Phase 3 (1st of January 2028) | • Mandatory for companies with turnover up to €800,000 |
Compliance Requirements
Companies must:
- Implement appropriate software for e-invoice issuance and delivery
- Ensure capability to receive e-invoices
- Maintain proper archiving systems
- Process corrections through electronic credit notes
Risks of Non-Compliance
Violations may result in:
- Penalties under Section 379 Paragraph 2 Numbers 1e and 1f of the Tax Code
- Potential civil claims from B2B customers
- Processing delays and business disruptions
How Mercator® by Citco (Mercator) Can Help
Mercator can assist with guidance on e-invoicing and compliance requirements across Germany and other jurisdictions. For assistance, please contact mercator@citco.com
