E-billing obligation 2025

As of 01.01.2025, electronic invoicing will be mandatory in the corporate sector.

What is an e-invoice?
An e-invoice is an invoice that is issued, transmitted and received in a structured electronic format, which enables electronic processing.

The e-invoice

• promotes automation and digitization in accounting,
• enables largely automatic and therefore faster processing of invoices,
• significantly reduces administrative and personnel costs,
• saves time and resources (paper) and thus also contributes to environmental friendliness and
• paves the way for future reporting portals and systems of the tax authorities, the purpose of which is to promptly notify the tax authorities of invoices (V model, Y model) and thereby curb fraud and abuse when issuing invoices.  

With the Growth Opportunities Act, a new legal regulation on the e-invoicing obligation was introduced in the German VAT Act. Accordingly, e-invoices must either meet the requirements of Directive 2014/55/EU and thus the EN 16931 standard or enable the complete and correct extraction of the required data.

Important: A PDF file is not an e-bill! PDF invoices are purely pictorial invoices. They do not meet the legal requirements. A PDF file does not contain any structured data and therefore cannot be processed electronically by automated means. Accordingly, PDF invoices are “other invoices”. These will no longer be permitted in national invoice transactions between companies subject to VAT in the “B2B” sector from 2028 at the latest.
E-invoicing will be introduced gradually in accordance with the guidelines of the Growth Opportunities Act:

Mandatory e-invoicing: from January 1, 2025
The receipt of e-invoices will be mandatory from January 1, 2025. There are transitional regulations for sending from January 1, 2025 to December 31, 2027.

Who is affected?
All domestic companies that sell or provide taxable and taxable transactions to other domestic companies (business-to-business).

Who is not affected?
Companies with supplies and services to foreign entrepreneurs, supplies and services to non-entrepreneurs (private individuals) or supplies and services that are tax-free.
Companies with low-value invoices under 250 euros and ticket sales.

Transitional arrangements for shipping from January 1, 2025 to December 31, 2027

Phase 1 - January 1, 2025 to December 31, 2026

• The priority of paper invoices no longer applies.
• Any company can send e-invoices without the consent of the invoice recipient.
• However, they may continue to send paper invoices and, with the (implied) consent of the invoice recipient, other electronic invoices (PDF etc.).

Phase 2 - January 1, 2027 to December 31, 2027

• Companies with a previous year's turnover of more than 800,000 euros in the business-to-business (B2B) sector may only send e-invoices.
• Companies with a previous year's turnover of no more than EUR 800,000 may continue to send paper invoices or - with the (implied) consent of the invoice recipient - another electronic invoice format (e.g. PDF invoices)
• EDI procedures are also permitted.

Phase 3 - From January 1, 2028

• All companies in the domestic B2B sector must send e-invoices.

What the e-bill means for you

On the input side: 
From January 1, 2025, you must be ready to receive e-invoices and process them in your financial accounting systems.

Despite the voluntary introduction of e-invoicing from 2025, it can be assumed that (some) companies will convert their invoice formats on the outgoing side before the statutory e-invoicing obligation from 2027 or 2028. 

On the output side: 
For entrepreneurs with only private customers (B2C) or foreign entrepreneurs or for companies that only carry out tax-free transactions, there will be no changes to the invoice format from 2025 and therefore no need for action.

For all other entrepreneurs, the obligation to switch to e-invoicing applies until 01.01.2027 (or 01.01.2028).  

Crowe BPG - Our consulting services and consulting offers

Depending on your services and your customer base, we will provide your company with an individual overview of the legal obligations and legal options for invoicing from 2025.
We will implement the receipt of incoming invoices in e-invoice format for your company as of 01.01.2025 and advise you on the various software solutions.

We will ensure that your company sends outgoing invoices in e-invoice format and advise you on the various software solutions. We also work with you to draw up concepts that ensure that invoicing is carried out in the correct format for different customer groups (B2B, B2C) and for mixed services (invoicing for tax-free and taxable services; invoicing for services that are used for both business and non-business purposes). 

We also provide ongoing advice on all application issues relating to the invoicing software that arise after implementation.

Thanks to the interdisciplinary team of tax consultants and IT consultants, Crowe BPG is able to provide comprehensive advice on the topic of “e-invoices”, from the legal requirements to practical software implementation. 

For you as a client, our advice offers the following added value: 
LEGAL SECURITY through compliance with legal requirements regarding the receipt and sending of invoices,

EFFICIENCY GAINS and COST SAVINGS by switching to e-billing.

Please contact us if you have any questions. 

Crowe BPG Beratungs- und Prüfungsgesellschaft mbH
Phone: 02151 508 400
E-mail: info@crowe-bpg.de