Germany seeks EU approval for nationwide mandatory B2B e‑invoicing

1. Germany’s derogation request to the European Commission

Public statements from the German authorities confirm that Germany intends to introduce a countrywide CTC‑style model for B2B transactions and has communicated this plan to the European Commission. To make such a system legally possible under EU law, Germany has formally asked the Commission for a derogation from Articles 218 and 232 of the 2006 VAT Directive, which govern the use and form of invoices in the EU.​

If granted, this derogation would allow Germany to require mandatory electronic invoicing for domestic B2B transactions, overriding the usual rules that give parties more freedom to choose invoicing formats and require buyer consent for e‑invoicing. Information about the European Commission and its role in this process can be found here: European Commission – official portalopen_in_new.​

2. Link to the EU “VAT in the Digital Age” (ViDA) initiative

Germany’s derogation request is closely aligned with the EU’s broader “VAT in the Digital Age” (ViDA) initiative. ViDA is an EU‑level project examining how VAT rules should evolve to reflect digitalisation, including real‑time reporting, e‑invoicing and platform economy measures.​

The German request appears to anticipate and support the direction of travel under ViDA by moving towards structured e‑invoicing and digital reporting as the norm for B2B supplies. Background and consultation documents on ViDA are available here: VAT in the Digital Age (ViDA) – European Commissionopen_in_new.​

3. Why this is an important milestone

Requesting a VAT Directive derogation is a significant step, both for Germany and for the EU as a whole, because:​

• It signals Germany’s intention to transition from a post‑audit environment to mandatory B2B e‑invoicing and possibly real‑time or near real‑time reporting.​
• It contributes to an emerging EU trend towards CTC models and harmonised digital reporting, which could influence future EU‑wide rules under ViDA.​
• It encourages businesses operating in Germany to start planning for structured, EN 16931‑compliant e‑invoices and integrated reporting capabilities as part of their medium‑term VAT compliance strategy.​

Once the Commission has assessed the request, further legislative and technical details will be published through EU and national channels, defining the exact scope and timing of Germany’s future B2B e‑invoicing obligations.