E-billing is coming – and with it, many questions
From 2025, eInvoicing will be mandatory in German B2B business. The digitization of invoicing is now finally a reality – and the new draft BMF letter provides greater clarity for companies, software providers, and tax advisors. But what exactly is changing? Where are the opportunities, and where are the question marks? And what does this mean for everyday business life?
We provide an overview of what is specifically regulated in the current BMF draft, where uncertainty remains – and how companies can now position themselves optimally. At the end of the article, you will find our white paper as a PDF download, which analyzes all changes in detail and provides practical implementation tips.
Overview: The most important changes in the BMF letter on electronic invoicing
Obligation to issue invoices – now also applies to small businesses
One of the most notable clarifications: The e-invoicing requirement now explicitly applies to small businesses and companies that generate tax-exempt sales. The previously much-discussed exception is thus no longer valid—everyone is covered.
Technical requirements & formats
The BMF specifies that, in addition to XRechnung, so-called extensions are also permitted in order to flexibly map industry-specific requirements. For those who use ZUGFeRD: In the hybrid format, the structured XML data record now always takes precedence over the PDF part – this ensures greater legal certainty and transparency in processing.
Email remains a means of transmission – but is not a solution for the future
Electronic invoices can still be received via email. A special mailbox is not necessary. However, companies are clearly expected to create the technical conditions necessary to receive and process eInvoices—and those who are unable to do so will no longer be entitled to receive alternative (paper) invoices in the future.
Dealing with errors and archiving
What is new is that invoices with formatting errors are no longer eligible for input tax deduction—unless special transitional provisions apply or an invoice is corrected. It has also been clarified that archiving outside of GoBD-compliant systems remains permissible, provided that the immutability of the data is ensured.
What remains unclear: the digital reporting system as the missing piece of the puzzle
Despite many details, one crucial point remains unclear: the planned digital reporting system for tax-related data is not addressed in this BMF draft either. Industry associations and experts had expected clear guidelines on this issue. Interoperable platform and network models—such as Peppol, which has long been standard in other EU countries—are also not explicitly mentioned.
This leaves companies uncertain about how the next stage of digitalization – namely the automated reporting system – will be structured in concrete terms. However, one thing is clear: those who digitize their processes now will lay the foundation for responding quickly and flexibly to future requirements.
Practical tips: What companies and software manufacturers should do now
- System check & update: Check your current ERP, accounting, or industry-specific software. Does it support the transmission and processing of e-invoices in accordance with EN 16931? Are all mandatory fields and formats covered?
- Process integration: Integrate e-invoicing solutions into your existing workflows. Make sure that all departments—from accounting to IT—are involved.
- Communication with partners: Talk to your business partners and service providers about the new requirements and ensure a smooth transition.
- Prepare for future reporting requirements: Actively monitor developments relating to the reporting system. Solutions such as TRAFFIQX® already offer a future-proof basis for this today.
