Germany advances B2B e‑invoicing under Growth Opportunities Act

1. Legislative status and political process

Mandatory B2B e‑invoicing in Germany is anchored in the Growth Opportunities Act (Wachstumschancengesetz). The German Parliament (Bundestag) first passed the law on 17 November 2023, but the Bundesrat (representing the federal states) did not approve it and instead referred it to the German Mediation Committee for further negotiation between the two bodies.​

Following these discussions, the Bundestag accepted the Mediation Committee’s proposals on 23 February 2024, without changing the core timeline for implementing the B2B e‑invoicing mandate. The Bundesrat was scheduled to vote on the revised act again on 22 March 2024, with expectations that the e‑invoicing provisions would ultimately move forward due to their revenue and compliance benefits. Background on the legislative dossier is available here: Growth Opportunities Act – Bundestag dossieropen_in_new.​

2. Implementation timeline and phasing out of non‑EN‑compliant invoices

The updated timeline focuses on gradually eliminating paper and unstructured electronic invoices in favour of EN 16931‑compliant e‑invoices:

• From 1 January 2025 – EN‑compliant e‑invoice becomes the default (not yet mandatory)
  • All businesses must be ready to receive structured electronic invoices that comply with EN 16931.​
  • Suppliers may still issue:
    1. paper invoices,
    2. unstructured electronic invoices (e.g. PDF), and
    3. non‑EN‑compliant EDI invoices,
       but only with the buyer’s consent and subject to later phase‑out.​
  • EN‑compliant invoices effectively become the preferred standard, even though their use is not yet fully mandatory.
• From 1 January 2027 – Phase 1 of the phase‑out (large taxpayers)
  • Businesses with turnover above EUR 800,000 in the previous year can no longer issue invoices
    1. on paper or
    2. in unstructured electronic formats,
       even if buyers agree.​
• From 1 January 2028 – Phase 2 of the phase‑out (remaining taxpayers)
  • All remaining businesses are likewise prohibited from issuing
    1. paper invoices or
    2. unstructured electronic invoices,
       again with no buyer‑consent exception.​

In parallel, country‑level guidance indicates that only EN 16931‑compliant e‑invoices will ultimately be accepted for in‑scope domestic B2B transactions, with EN formats already referenced as the standard in EU documentation: Obtaining a copy of EN 16931open_in_new.​

3. Outlook and expected impact

Although the final vote on the Growth Opportunities Act was still pending at Bundesrat level at the time of the referenced update, the e‑invoicing parts are widely seen as likely to pass because they help close VAT gaps, increase tax revenue and drive automation across German businesses. Once fully implemented, the framework will make structured EN 16931 e‑invoices the default from 2025 and, over time, the only permitted format for domestic B2B invoicing, significantly reducing reliance on paper and ad‑hoc PDF invoicing.​

For companies operating in Germany, this means preparing systems to receive EN‑compliant invoices by 2025, eliminating paper and unstructured formats in line with the 2027/2028 milestones, and planning for future digital reporting requirements that will likely be aligned with the EU’s “VAT in the Digital Age” reforms.​