Germany finalises guidance on mandatory eInvoicing from 2025
On 15 October 2024, Germany’s Ministry of Finance (BMF) published the final version of its guidance on issuing invoices under Section 14 of the German VAT Act (UStG).
The update outlines how mandatory electronic invoicing (eInvoicing) will work for domestic transactions between businesses, starting 1 January 2025.
Comparted to the draft released last June, the final version adds several clarifications and updates. Here are some of the key points:
Who’s affected?
- The guidance confirms which businesses and transactions fall under the eInvoicing requirement.
- Non-established businesses and some tax-exempt transactions are excluded.
- Low-value invoices (currently under €250) and travel tickets are also exempt.
How can eInvoices be sent?
Several transmission methods are acceptable, including:
- Electronic interfaces
- Shared access to a central storage location (e.g. within a company group)
- Download via a secure internet portal
The method must be agreed between the parties as part of the contract.
Does the invoice need to be human-readable?
If a business doesn’t have a German Tax ID (Steuernummer), it can use its Business Identification Number (W-IdNr.) instead.
What if there are small differences between invoice versions?
Minor inconsistencies between the eInvoice and a regular invoice (like a PDF) are allowed, as long as they don’t materially change the content. For example, slight differences in item descriptions are okay.
What about credit notes?
Regular invoices issued before 2025 can still be corrected with non-electronic credit notes, until the end of 2028.
- Credit notes can still be issued as “other invoices” for transactions outside the eInvoicing scope.
- For eInvoices issued from 2025 onward, credit notes must also be in electronic format.
- Regular invoices issued before 2025 can still be corrected with non-electronic credit notes—until the end of 2028.
How are advance payments handled?
VAT can be deducted as usual when the final invoice is issued, even if part of the payment was made earlier.
If an eInvoice is used to bill the remaining balance, it must follow the new rules from 1 January 2025. However, if there are technical barriers, regular invoices can still be used for these payments until 31 December 2027.
Special cases
For contracts like rental or lump-sum agreements with a tax advisor, a single eInvoice is enough at the start. Any later changes to the contract also require an eInvoice.
This is based on Article 14.5(17) of the UStAE, which allows payment receipts to act as proof of service in place of a formal invoice.
These changes take effect from 1 January 2025, with transitional rules lasting through 31 December 2027 for some situations.
Stay Up to Date
Each month we feature the latest news trends and topics covered by our experts. For more regular news and regulatory updates follow us on LinkedIn or sign up to our newsletter.
Work with indirect tax experts
Navigating global indirect tax doesn’t have to be complicated. At Fintua, our dedicated team brings clarity to compliance. Whether you’re expanding into new markets or streamlining existing obligations. We combine expert insight with tailored technology to support businesses in a digital-first landscape. Whatever the jurisdiction, whatever the challenge – we’re ready.
