Germany shifts nationwide B2B e‑invoicing start to 2026

1. New proposed start date for the mandate

Germany has already obtained EU permission (derogation) to introduce mandatory e‑invoicing for the private sector from 2025, but the Ministry of Finance (Bundesministerium der Finanzen – BMF) is now proposing to postpone the go‑live to 1 January 2026. This change follows a public consultation held on 8 May 2023, during which stakeholders raised implementation concerns and practical considerations.​

Information on the BMF and upcoming legislative work can be found on the ministry’s official site: Bundesministerium der Finanzenopen_in_new.​

2. Interaction with ViDA and structured invoice requirements

Even with the revised 2026 date, the adjusted timeline remains consistent with the EU “VAT in the Digital Age” (ViDA) initiative. From 2025, only structured invoices will be considered electronic invoices for German VAT purposes, and taxpayers will be allowed to exchange e‑invoices voluntarily even before the mandate becomes fully binding.​

Under ViDA, it is expected that formats compliant with the European standard EN 16931 will become mandatory by 2028, which matches Germany’s planning horizon. Technical details on EN 16931 compliance are available here: EN 16931 complianceopen_in_new.​

3. Outlook for the CTC model and reporting

So far, the authorities have not yet published detailed information on the final CTC (continuous transaction control) model Germany will adopt for B2B transactions. What is clear is that the country is moving towards a phased approach: first defining structured e‑invoices and allowing voluntary use, then introducing a nationwide obligation, and ultimately aligning national reporting with ViDA’s EU‑level framework.​

Businesses should therefore prepare their systems to generate and process EN 16931‑compliant structured e‑invoices and to support future electronic reporting, even though the exact shape of the German CTC model is still to be confirmed.