Germany: New ZUGFeRD version 2.3.2; FAQs for e-invoicing mandate
Release of a new version that can be used for electronic invoice (e-invoice) exchange announced
The Forum (elektronische Rechnung Deutschland (FeRD))—the entity that releases the standard of the ZUGFeRD e-invoicing format in Germany—on November 13, 2024, announced the release of a new version 2.3.2 that can be used for electronic invoice (e-invoice) exchange.
The ZUGFeRD is a hybrid format of electronic invoice that is authorized for complying with the e-invoicing mandate of the country. This new version was chosen to align with the French release Factur-X 1.07.2, providing international compatibility.
Key changes in ZUGFeRD version 2.3.2 include:
- Updated code lists and validation rules: The European Committee for Standardization (CEN) published new code lists and corrected technical checks, which must be applied from November 15, 2024. These changes have been incorporated in the patch release to provide the conformity of the ZUGFeRD standard.
- Definition and expansion of the hybrid document format: ZUGFeRD enables the creation of standardized hybrid documents by embedding an electronic document in XML format within a PDF/A-3 file. The standard defines both a CIUS BASIC compliant with EN 16931 and a "conformant" extension that provides additional functionalities. Both parts of the standard can be used independently, allowing, for example, the extended profile in XML format to be used as an e-invoice on its own.
- Highlighting BR-HYBRID-XX rules: To clarify the rules for creating hybrid documents, the requirements described in the text have been compiled into a table. This table is located in the specification's appendix and not in the technical appendices, as these rules are specific to ZUGFeRD and not part of the EN 16931 business rules.
In addition, the following recommendation is made for the use of standardized namespace prefixes:
- The syntaxes UBL and CrossIndustryInvoice (CII), which are relevant for EN 16931, recommend using standardized prefixes.
- For UBL, the recommended prefixes are "cac" and "cbc".
- For CII, the recommended prefixes are "rsm", "ram", "qdt", and "udt".
Although these prefixes are not mandatory according to the XML standard, using alternative prefixes can often cause issues for recipients. Therefore, it is recommended to use these standardized prefixes to ensure interoperability. Previous versions remain valid, but support for version 2.2 ended with the release of version 2.3 on September 17, 2024. It is recommended to update to the new version.
FAQs for e-invoicing mandate
In a separate publication, the German Ministry of Finance on November 19, 2024, posted online “frequently asked questions” (FAQs) regarding the introduction of mandatory e-invoicing for sales made after December 31, 2024, as detailed in BMF Letter No. 2024/0883282. Topics covered include:
- The requirement for electronic invoices to be regularly used for sales between domestic entrepreneurs from January 1, 2025
- Transitional provisions allowing paper and certain alternative invoices from January 1, 2025, to December 31, 2026
- The exemption of private end consumers from the electronic invoicing requirements
- The requirement for routing IDs for electronic invoices sent from business to government (B2G), but not from business to business (B2B)
- The application of mandatory electronic invoicing if there is a value added tax (VAT) requirement to issue an invoice, but not in certain cases like for small amounts up to €250 ($263 USD)
- Requirements for formats and electronic processing
For further information, contact a KPMG tax professional:
Kathya Capote Peimbert | kcapotepeimbert@kpmg.com
Philippe Stephanny | philippestephanny@kpmg.com
Ramon Frias | ramonfrias@kpmg.com