German FDP proposes nationwide e‑invoicing clearance system

1. FDP proposal for a nationwide e‑invoicing platform

The FDP has submitted application 19/26534 to the German Bundestag, requesting the creation of a countrywide e‑invoicing system based on the Italian Sistema di Interscambio (SDI) infrastructure. The full application text can be consulted here: FDP Bundestag application 19/26534 (PDF)open_in_new.​

The initiative comes only a few months after e‑invoicing became mandatory for suppliers to the German Federal Government, signalling a potential next step from a B2G obligation to a much broader nationwide model. In its request, the FDP highlights the advantages of clearance procedures, where e‑invoices are transmitted to a government‑appointed service, automatically verified and then forwarded to the recipient.​

2. Expected benefits and reference to Italy’s SDI

In its justification, the FDP points to the experience of Italy, which has introduced a comprehensive clearance‑based e‑invoicing regime through SDI. Italy’s system is cited as an example of how real‑time controls can:​

• Reduce value‑added tax (VAT) fraud by giving tax authorities transaction‑level visibility.
• Simplify invoicing processes for businesses once integrated into their ERP and e‑invoicing solutions.
• Cut down on bureaucratic complexity through standardisation and automated checks.

Further background on Italy’s framework can be found here: Italy – Regulatory overviewopen_in_new.​

However, implementing such an extensive clearance and mandatory e‑invoicing model would require Germany to obtain a derogation from the EU VAT Directive. This would involve applying to the European Commission under the rules described in the VAT Directive Derogation decision, available at: Council Implementing Decision on VAT derogationopen_in_new.​

3. Scope of the proposed e‑invoicing mandate

The FDP’s request envisages a nationwide system and does not specify any particular exclusions or carve‑outs. In other words, the proposal implies a broad mandate that could potentially cover most, if not all, domestic transactions if implemented as suggested.​

This contrasts with the Italian approach, where e‑invoicing was phased in gradually, starting with certain sectors and categories of taxpayers before becoming widely applicable. The reference to Italy in the application therefore highlights both the potential benefits and a different sequencing strategy compared to what the FDP is currently asking for.​

4. Call for prioritisation and next steps

In its application, the FDP explicitly calls for the introduction of the nationwide e‑invoicing and clearance system to be treated as a high‑priority project. The party urges that design and implementation should proceed as quickly as possible in order to realise efficiency gains and strengthen VAT control in Germany.​

If pursued by the Federal Government, next steps would likely include:​

• Drafting a detailed legal framework and technical specifications for a German clearance platform.
• Coordinating with the European Commission to secure the necessary VAT Directive derogation.
• Consulting with businesses, solution providers and industry associations on implementation timelines and integration requirements.

For companies operating in Germany, the proposal is a strong signal that the country is considering a move towards more real‑time VAT controls and broader mandatory e‑invoicing, similar to leading clearance countries like Italy