German B2B e‑invoicing mandate: current status and timelines

1. Policy focus and regulatory approach

For years, the shape of Germany’s mandatory B2B e‑invoicing regime was uncertain, but the cabinet draft published on 29 August 2023 and subsequent guidance from the Federal Ministry of Finance have clarified the main direction. Unlike some neighbouring countries, Germany has not yet fixed a specific CTC model for its future Digital Reporting Requirement (DRR) and is instead waiting for more certainty from the EU’s “VAT in the Digital Age” (ViDA) initiative.​

In the meantime, the mandate will first reshape the e‑invoicing landscape by regulating which e‑invoice formats are allowed and how buyer consent is handled. The emphasis is on making EN 16931‑compliant structured e‑invoices the default and then the only acceptable format for domestic B2B invoicing.​

2. Timeline for phasing out non‑EN‑compliant invoices

The current roadmap introduces a stepwise transition from today’s mixed formats to full EN‑compliance:

• From 1 January 2025 – EN‑compliant e‑invoice becomes the default (not yet fully mandated)
  • All businesses must be able to accept EN 16931‑compliant e‑invoices (for example XRechnung), and suppliers may send such invoices (including EN‑compliant EDI) to any buyer without prior consent.​
  • Suppliers can still issue:
    1. paper invoices,
    2. invoices in unstructured formats (such as PDF), and
    3. non‑EN‑compliant EDI invoices,
       but these are earmarked for gradual phase‑out.​
  • Use and exchange of unstructured and non‑EN‑compliant EDI invoices remains possible only with the buyer’s explicit prior consent.​
• From 1 January 2026 – Phase 1 of the phase‑out (large taxpayers)
  • Businesses with turnover above 800,000 EUR in the previous year may no longer issue invoices
    1. on paper or
    2. in unstructured electronic formats,
       even if the buyer consents.​
• From 1 January 2027 – Phase 2 (all remaining businesses)
  • All other businesses are likewise prohibited from issuing
    1. paper invoices or
    2. unstructured electronic invoices,
       again without exceptions for buyer consent.​
• From 1 January 2028 – Phase 3 (full EN‑compliance)
  • Only EN 16931‑compliant e‑invoices may be issued, exchanged and received for in‑scope transactions.​
  • EDI e‑invoices that do not comply with EN 16931 will no longer be permitted, even with agreement between trading parties.​

The Ministry of Finance has indicated that these phase‑out dates could be adjusted depending on market feedback and implementation experience.​

3. Open points: transport channels, DRR and Peppol

For now, the regulator has not prescribed a single transport or exchange mechanism for e‑invoices, which means that, in principle, even email can be used as a delivery channel despite its manual and less secure nature. At the same time, the Peppol network is gaining traction in Germany on both the B2G and B2B sides, making it a strong candidate for businesses seeking a scalable, interoperable framework for issuing, exchanging and receiving e‑invoices.​

The draft legislation does not yet define the Digital Reporting Requirement (DRR) in detail, but Germany is widely expected to model its reporting architecture on whatever final approach the EU adopts under ViDA. This points towards a future in which EN 16931‑compliant e‑invoices serve not only as the standard commercial document but also as the primary data source for electronic VAT reporting.