Germany’s planned B2B e‑invoicing mandate: key draft highlights

1. Timelines for e‑invoice introduction

The updated draft legislation from the Federal Ministry of Finance (Bundesministerium der Finanzen – BMF) defines a two‑step timeline for rolling out mandatory e‑invoicing:​

• From 1 January 2026, EN‑compliant e‑invoices become the default or primary type of electronic invoice in Germany; EDI invoices remain possible, but only if the buyer explicitly consents.​
• From 1 January 2028, only EN‑compliant e‑invoices will be permitted, meaning EDI invoices will no longer be allowed even with buyer consent.​

These dates apply to all affected businesses at the same time; the draft does not provide for a phased or size‑based rollout.​

2. Scope of taxpayers and invoices

The proposed mandate targets the following:​

• Taxpayer scope: All businesses established in Germany, including fixed establishments, that are required to issue invoices for their sales.​
• Invoice scope: The rules apply to the issuance and exchange of domestic “complete” invoices.​

Certain transactions are out of scope of this draft:​

• Cross‑border invoices, including intra‑Community transactions.
• Simplified invoices with a value of less than 250 EUR.​

This means the core obligation focuses on domestic B2B invoices between German‑established taxpayers.

3. Transmission channels and integrity/authenticity

The draft does not regulate the transmission channel for e‑invoices, so businesses remain free to choose how they exchange structured invoices, including via email, service providers or direct connections.​

Requirements for integrity and authenticity of e‑invoices remain unchanged. Businesses can continue to rely on any of the following three options:​

• Business controls (reliable audit trail).
• EDI processes.
• Electronic signatures.

This continuity allows companies to leverage existing control frameworks while adopting EN 16931‑compliant formats.

4. Digital Reporting Requirement (DRR) outlook

The draft law is silent on a detailed Digital Reporting Requirement (DRR), so no concrete national reporting model is specified yet. Nonetheless, it is expected that Germany will align closely with whatever DRR structure is ultimately set at EU level under the “VAT in the Digital Age” (ViDA) framework.​

In practice, this means businesses should plan for a future where structured EN 16931 e‑invoices are not only exchanged between trading partners but also form the basis of electronic reporting to the tax administration, once DRR rules are finalised.