Germany introduces nationwide B2B e‑invoicing from 2025

1. Legislative approval and overall mandate

Germany’s legislative process for B2B e‑invoicing has concluded with a clear green light for the mandate. The Bundesrat, representing the federal states, has approved the Growth Opportunities Act (Wachstumschancengesetz), which embeds the B2B e‑invoicing obligation into German law. The Bundestag had already voted in favour of the Mediation Committee’s compromise on 23 February, so with the Bundesrat’s approval the Act is now passed and e‑invoicing in the business sector becomes obligatory from 1 January 2025.​

Official communication on the Bundesrat’s decision is available here: Bundesrat – decision on Wachstumschancengesetzopen_in_new. Background on the law itself can be found in the Bundestag’s legislative file: Growth Opportunities Act – Bundestag dossieropen_in_new.​

The law also makes the mandatory use of electronic invoices a prerequisite for a later obligation to report transaction‑level B2B sales data to a standardised national electronic reporting system.​

2. Implementation timeline and phase‑out logic

The Act sets out a staged transition from today’s mixed invoicing practices to full reliance on EN 16931‑compliant e‑invoices for domestic B2B transactions:​

• From 1 January 2025 – EN‑compliant e‑invoice becomes the default
  • All businesses must be able to receive structured electronic invoices that comply with EN 16931.​
  • Suppliers may still issue:
    1. paper invoices,
    2. invoices in unstructured formats such as PDF, and
    3. non‑EN‑compliant EDI invoices,
       but only with the buyer’s consent and with the understanding that these formats will be phased out according to the steps below.​
  • EN‑compliant e‑invoices are thus elevated to the default standard, even though alternative formats remain temporarily permissible.
• From 1 January 2027 – Phase 1 of phasing out non‑EN‑compliant invoices
  • Businesses with turnover greater than EUR 800,000 in the previous year are no longer allowed to issue invoices
    1. on paper, or
    2. in unstructured electronic formats,
       even where buyers would still accept them.​
• From 1 January 2028 – Phase 2 of phasing out non‑EN‑compliant invoices
  • All remaining businesses are likewise prohibited from issuing
    1. paper invoices, and
    2. unstructured electronic invoices,
       again without any buyer‑consent exception.​
  • In addition, EDI e‑invoices that are not compliant with EN 16931 will no longer be allowed.​

A description of how to obtain the EN 16931 standard itself is available from the European Commission: EN 16931 – European e‑invoicing standardopen_in_new.​

3. Link to future reporting and practical implications

The newly mandated e‑invoicing model is explicitly designed as a foundation for a later transaction‑based reporting system, where data from B2B e‑invoices will be transmitted to a national electronic platform. While the detailed Digital Reporting Requirement (DRR) will be defined in separate regulations, the law makes clear that electronic invoicing is a precondition for that future reporting obligation.​

For businesses, this means:​

• Ensuring they can receive EN 16931‑compliant invoices from 2025.
• Planning to eliminate paper and unstructured formats in line with the 2027/2028 turnover‑based phase‑out.
• Preparing ERP, billing and e‑invoicing solutions to support fully structured formats that can later feed into a national reporting system aligned with EU “VAT in the Digital Age” principles.