Infothek

Discussion on mandatory B2B e-invoicing in Germany as early as 2025

The vehicle to implement the changes mentioned below is apparently Article 27 of the draft of the Growth Opportunities Act. In the meantime I published a more detailled text which mentions this and puts the events into the correct chronological order: in this original text the last paragraph has the earliest events.

In the joint FNFE/AWV workshop in Strasbourg on April 20th/21st 2023, "Vat in the Digital Age", ViDA, was a topic and Jenny Herzfeld mentioned that Germany had already requested Art. 395 MwStSystRL permission to introduced mandatory B2B-e-invoicing in November 2022, and that the expected "discussion proposal" (Diskussionsvorschlag) for the introduction in January 2025 had arrived on Tuesday, April 18th, 2023.

This is backed by the fact that a local chamber of commerce has published identical information with the detailled changes suggested for the Umsatzsteuergesetz.

On May 22nd, 2023, the leading associations published a joint opinion on that request: 2025 would be too early, hybrid invoices should be considered and reliable mandatory e-invoicing should be implemented before the Continuous Transaction Control system (CTC) (Umsatzsteuermeldesystem), instead of afterwards (as indicated by the scientific service, see below).

Previously there had already been a (german) paper how the Italian approach on e-invocing could also be applied on Germany, the Federal Audit Office (Bundesrechnungshof) mentioned it, the Scientific Service of the Bundestag investigated and a political party even requested mandatory B2B invoicing in Germany. In the 2021 coalition treaty to form the newly elected German government the parties agreed to introduce a CTC. 

Update 2023-05-23: Replaced two now broken original links RE discussion proposal with working ones from archive.org

Update 2023-06-12: Added two sentences on the opinion of the leading associations.

Update 2023-08-30: Added the first paragraph with the link to the article mentioning the draft of the Growth Opportunities Act.