Germany has finally approved the Growth Opportunities Act, which outlines the schedule for Business-to-Business (B2B) e-invoicing in the country. This has followed months of uncertainty, as both the Upper and Lower Parliament Houses failed to reach consensus on a final vision for e-invoicing in Germany.

Despite other key territories taking prominence in the e-invoicing community in recent months, such as Romania, Malaysia and Poland, Germany has propagated an ambitious timeline, with e-invoicing receipt obligations set to take effect from 1 January 2025. From this date, German businesses must have the capability to receive e-invoices which confirm to the European standard, the EN16931.

In terms of a full, comprehensive timetable:

• January 2025: E-invoice receipt obligations commence, with businesses obligated to accept invoices in accordance with the European norm. Buyer consent will be required for all other invoice formats. Limited exceptions apply, including invoices for under 250 Euros and specific tickets. German taxpayers may voluntarily issue e-invoices from this point.
• January 2025 - 31 December 2026: Paper is still permitted, as well as e-invoices that do not comply with the EU norm. However, paper invoices no longer have priority.
• January 2027: Mandatory e-invoicing for companies with a turnover of over 800,000 Euros.
• January 2028: Mandatory e-invoicing for remaining taxpayers.

Tungsten Automation is acutely aware the January 2025 is impending, and our preliminary analysis has already unearthed some outstanding, critical questions. Notably, while the mandate enforces an invoice format that complies with the European norm, the method of transmission has not. We are awaiting clarification of this, alongside other elements of the process, including if and how the current established Business-to-Government (B2G) infrastructure will influence Germany’s B2B e-invoicing trajectory.

Tungsten Automation will prioritise an analysis of further information provided by the German government once published given the deadline, and we are urgently assessing how we can assist our German market considering these new obligations.