German Ministry of Finance Releases E-Invoicing Guidelines for 2025 Rollout

On October 15, 2024, the German Ministry of Finance released the finalized guidelines for mandatory electronic invoicing between domestic businesses, effective January 1, 2025. This official version refines the June draft, clarifying key elements under the Growth Opportunities Act (Wachstumschancengesetz) and marking the final step towards full implementation.

Timeline

The final guidelines leave the key requirements unchanged and confirm that the obligation to receive e-invoices will begin as planned on January 1, 2025.

the German Ministry of Finance released the finalized guidelines for mandatory electronic invoicing between domestic businesses, effective January 1, 2025

Impact

The finalized guidelines have clarified several aspects of the upcoming e-invoicing requirement, introducing key updates such as:

• ZUGFeRD profiles MINIMUM and BASIC-WL are excluded from compliant formats under EN 16931.
• Peppol BIS Billing has been added as a permitted e-invoice format.
• Invoice issuers can rely on recipients' VAT ID numbers to determine domestic entrepreneurial status, unless there is contradictory information.
• The e-invoicing obligation applies even if only part of the services is taxable, such as partially taxable and tax-exempt transactions under Section 4 (8) to (29) UStG.
• More details are provided on the use of qualified electronic signatures, EDI procedures, or internal control systems to ensure the authenticity and integrity of invoices.
• There is greater emphasis on trading parties agreeing on the e-invoice format and transmission method in accordance with civil law.
• Possible transmission options include email, electronic interfaces, shared storage locations, and internet portals.
• E-invoicing platforms will play a key role in real-time data reporting, though specific timelines for the reporting obligation are not yet provided.