Mandatory e-invoicing for domestic B2B transactions in Germany now envisioned for 2026 onwards

In accordance with Directive 2014/55/EU and CEN-standard 16931, all businesses invoicing another - provided that the transaction is taxable in Germany and both businesses are German resident - will be required to use e-invoices as of 1 January 2026, ie, before the 2028 deadline set by the European Commission.

Until 31 December 2025, paper and PDF invoices will remain authorised.

In addition to this new timeframe, the Growth Opportunities Act proposal contains further clarifications. In particular, an “e-invoice” is defined as an invoice issued, transmitted and received in a structured electronic format that enables electronic processing. So-called “other invoices” include all other invoice formats such as paper or PDF invoices.

For other electronic invoices transmitted via an EDI interface, the CEN standard 16931 will only be applicable from 1 January 2028. This means that, up to that date, invoices can also be issued and sent as “other invoices” in another electronic format with the consent of the recipient if an EDI interface is used.

Key takeaway

Businesses should soon prepare to configure or upgrade their billing systems and processes to be able to issue e-invoices in accordance with CEN-standard 16931. Paper and PDF invoices will no longer be accepted when e-invoicing becomes mandatory from 1 January 2026.

Readers who are interested to know more about the Growth Opportunities Act and upcoming changes in German VAT law may read our more detailed article on the Growth Opportunities Act.

Reference: Wachstumschancengesetz (Growth Opportunities Act)