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E-Invoices for B2B Transactions – New Requirement in Germany from 2025.
(English image not yet available)In the EU, and thus in Germany, electronic invoices in the B2B sector will soon be mandatory. The first step in Germany is the requirement to receive E-Invoices starting from 2025. Here, we provide an overview of the plan and status for Germany – and how it is considered in MOCO (updated 25.11.24).
Timeline for Germany
The introduction will occur gradually from January 1, 2025:
Step 1 from 01.01.2025 – Incoming Invoices
Every entrepreneur receiving services from other domestic entrepreneurs must be able to receive and process E-Invoices (the previously required consent to receive an E-Invoice is no longer necessary).
Every entrepreneur receiving services from other domestic entrepreneurs must be able to receive and process E-Invoices (the previously required consent to receive an E-Invoice is no longer necessary).
Step 2 from 01.01.2027 – Outgoing Invoices
Various transitional periods are planned for the creation of E-Invoices (§ 27 Abs. 39 UStG-E): Until the end of December 2025, paper and PDF invoices are still permitted. If turnover is below 800,000 EUR in 2025, the deadline extends to the end of 2026. By January 1, 2027, paper and PDF invoices in the B2B sector should be a thing of the past.
Various transitional periods are planned for the creation of E-Invoices (§ 27 Abs. 39 UStG-E): Until the end of December 2025, paper and PDF invoices are still permitted. If turnover is below 800,000 EUR in 2025, the deadline extends to the end of 2026. By January 1, 2027, paper and PDF invoices in the B2B sector should be a thing of the past.
This means for you: Your company must be able to receive an E-Invoice after the turn of the year.
Background: EU Initiative
The EU Commission has taken initial steps to curb VAT fraud with the VAT in the Digital Age Initiative (ViDA). The introduction for the entire EU is planned for January 1, 2028.
In Italy, for example, the E-Invoice has been mandatory for some time and is very successful in reducing tax fraud.
Germany now also plans to gradually introduce the mandatory E-Invoice for national B2B transactions from January 1, 2025, as part of the Growth Opportunities Act.
In Italy, for example, the E-Invoice has been mandatory for some time and is very successful in reducing tax fraud.
Germany now also plans to gradually introduce the mandatory E-Invoice for national B2B transactions from January 1, 2025, as part of the Growth Opportunities Act.
"VAT in the Digital Age (ViDA)" Overview
- Measure: The introduction of the E-Invoice for intra-community transactions – the E-Invoice should become standard.
- Timeline for Introduction: From January 1, 2025, specific requirements for an E-Invoice apply: A structured electronic format in XML that enables automatic and electronic processing. From 2025, transmission should occur without the recipient's consent.
- Transitional Regulations until 2028: Paper invoices and other electronic formats (e.g., PDF) are temporarily still accepted.
- Mandatory from January 1, 2028: The E-Invoice will be mandatory for intra-community transactions from January 1, 2028.
- Mandatory Information: IBAN of the service provider and payment due date.
- Challenges: Collective invoices will no longer be allowed, and invoicing should occur no later than 2 working days after service delivery.
There is political resistance. The Economic Policy Committee (ECON) proposes at least a one-year delay, and the EU Parliament advocates for a relaxation of the timeline. Therefore, the final timeline is currently uncertain.
Implementation in Germany: The Growth Opportunities Act
- Measure in Germany: EU member states are now striving for national-level introduction. Germany wants the Bundestag to comprehensively revise § 14 of the VAT Act (UStG) with the Growth Opportunities Act and establish the E-Invoice for national B2B services in Germany as the standard procedure. The Bundesrat's approval occurred on March 22, 2024.
- Affected are: Domestic B2B transactions: Services according to § 1 Abs. 1 Nr. 1 UStG, provided both parties involved (entrepreneurs) have their headquarters, management, a VAT-relevant permanent establishment, or their residence or habitual abode in Germany. This is required according to § 14 Abs. 2 Satz 6 UStG-E.
- Exceptions: According to the draft, small amount invoices up to 250 euros and travel tickets.
Definition of the E-Invoice
The draft law defines an E-Invoice as an invoice issued, transmitted, and received in a structured electronic format that enables electronic processing.
OLD: Paper and PDF Invoice
NEW: Structured format that enables electronic processing
NEW: Structured format that enables electronic processing
In principle, the well-known hybrid formats XRechnung and ZUGFeRD (from version 2.2) meet the planned legal requirements.
- XRechnung: It is a data format that has already been established in public procurement (B2G).
- ZUGFeRD: The format generates, as a so-called hybrid format, an XML file as well as a PDF file readable by the human eye.
MOCO + E-Invoice
More and more companies expect their business partners to be able to receive and send electronic invoices. Therefore, the pressure to switch is growing, regardless of national or EU legislative timelines.







