German Federal Council (Bundesrat) has recently published the Growth Opportunities Act (Wachstumschancengesetz), which aims to strengthen growth opportunities, investment and innovation as well as tax simplification and tax fairness.

Within this legal context, e-invoicing will become mandatory for German companies from 1^st January 2025, even though some transitional provisions and exceptions are included in the Act. Invoices will need to be issued, transmitted, and received in a structured electronic format that enables electronic processing, in compliance with European standards adopted with the EN 16931.

The Act establishes a defined timeframe for the implementation of e-invoicing:

• From 1^st January 2025, all companies must be able to receive e-invoices. Nevertheless, other invoicing formats may still be used until 31^st December 2026, provided that the invoice recipient agrees.
• From 1^st January 2027, issuance of e-invoices will be mandatory for companies with an annual turnover exceeding 800.000 EUR.
• Finally, from 1^st January 2028, issuance of e-invoices will be mandatory for all companies operating within Germany.

The use of electronic invoicing is already in force since 2020 for public procurement of the state authorities.

Additionally, in order to promote a smooth adaptation to the new requirements, Ministry of Finances has published a draft guide on electronic invoicing matters, which is already available for consultation. After review of associations, the final version is expected to be published in the last quarter of 2024.

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