Germany: Consultation on implementation of B2B e-invoicing requirement effective 2025

Comments are due by 8 May 2023.

Comments are due by 8 May 2023.

The German Ministry of Finance on 17 April 2023 issued a discussion document for consultation on a proposal to implement an electronic invoicing (e-invoicing) mandate for business-to-business (B2B) transactions effective 2025. 

Comments are due by 8 May 2023.

The proposal would be based on the framework of the Value Added Tax in the Digital Age (ViDA) proposal of the European Commission. E-invoices would not need to be validated by the government before being sent to the customer. The exchange of e-invoices would take place either via a government e-invoice platform or via private e-invoice platforms that certain requirements so that the remittance of the invoice data to the tax authorities would be made at the same time it is to the customer. 

While the draft of the law that would implement the mandate has not been published yet, the Ministry of Finance indicated that the tax and commercial laws would be modified to: 

  • Make e-invoices, and not paper invoices, the default and mandatory system of invoicing for domestic B2B transactions
  • Define the concept of e-invoices based on the ViDA proposal and the EU Directive on e-invoicing in public procurement
  • Modify the legal definition of "invoice" so that it includes electronically issued invoices
  • Adjust the provisions of the laws that regulate the authenticity, origin, legibility, and integrity of the invoices. 

In terms of a timetable, the Ministry of Finance is planning to recommend to the parliament that the system be effective 1 January 2025. However, before sending the proposal to the parliament, the Ministry of Finance wants businesses, software providers, and other stakeholders to submit their comments and assessments, not only about the suggested effective date but also the deployment process of the system. In this respect, the Ministry of Finance would like to hear comments about whether the mandate should be deployed in phases, based on the size of companies, the amount on invoices, or some other alternatives, and applicable exceptions.

For more information, contact a KPMG tax professional in Germany:

Christoph Jünger |



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