Mandatory eInvoicing in the home stretch: Mediation Committee reaches compromise on the Growth Opportunities Act

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During the night of February 21–22, 2024, a compromise was apparently reached in the Joint Committee of the Bundestag and the Bundesrat. The Growth Opportunities Act (WCG), which has been scaled back in scope, now provides a relief package of just over three billion euros for the German economy. Originally, in the summer of 2023, the figure under discussion had been as high as seven billion.

As has been observed in recent months, one particularly promising aspect of the numerous “work in progress” items at the WCG received little attention during the latest deliberations as well: For, largely overlooked by political debate and the interested public, the amendment to the Value-Added Tax Act introducing mandatory eInvoicing in the B2B sector remains in a “hostage-like” holding pattern until the WCG finally secures an overall majority in favor of the bill.

And this amendment to the Value-Added Tax Act could soon lead to significant additional tax revenue. According to expert estimates, the switch to eInvoicing could generate annual additional revenue in the double-digit billions for the state coffers. This is because electronic invoice exchange enables more efficient control of input tax deductions by the tax authorities, which could significantly reduce the VAT gap in Germany.

Here are the key points regarding the eInvoicing requirement in Germany—for which no substantive changes were required as part of the compromise:

Start date and timeline for the eInvoicing requirement remain unchanged

Starting January 1, 2025, the acceptance of eInvoicing that complies with the EN16931 standard will become mandatory for all German B2B transactions. The previous preference for paper invoices will be phased out. Likewise, the requirement to obtain consent as a receiver for standard-compliant eInvoicing will no longer apply.

Of course, there are exceptions and transitional provisions:

For example, invoices for small amounts up to €250 and tickets are exempt from this rule, as are invoices issued to consumers.

Until the turn of the year 2026/2027, companies may continue to issue paper invoices and eInvoicing in non-standardized formats.

What happens next?

The successful conclusion of this compromise now depends on the approval of the Bundestag and the Bundesrat. While approval by the Bundestag is considered likely, the decision in the Bundesrat remains uncertain. This is particularly due to unresolved issues, such as the regulation of “agricultural diesel.”

These developments are a clear indicator of the importance of digitalization in the financial sector and demonstrate how legal adjustments can bring significant financial and operational benefits.

However, only invoicing companies with an annual turnover of more than 800,000 euros must fully implement the eInvoicing regulations by January 1, 2028. If turnover is below this threshold, the “grace period” for smaller businesses will not end until after this date.

For existing EDI systems that do not yet meet the requirements, a transition period until the end of 2027 has been granted.

Lars Becher, Portrait

About the Author

Lars Becher is a Key Account Manager and Subject Matter Expert for eInvoicing and CTC within the Traffiqx network at b4value.net. As a trainer, he is also responsible for various types of non-technical training sessions for Traffiqx providers. He earned his Master of Arts (MA) degree from Worms University of Applied Sciences.

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