Core Essentials of the BMF Draft
1. Implementation Timeline & Scope
Since January 1, 2025, all German companies must be able to receive e-invoices. The obligation to issue them starts in phases:
- 2027: Companies with >€800,000 turnover.
- 2028: All other companies (excluding small businesses).
- 2028: EDI-transmitted invoices must also comply with the EN 16931 standard.
2. Handling Errors & Compliance
Syntax Errors: Invoices failing the technical structured format (EN 16931) will be classified as "other invoices," potentially risking input VAT deductions after transitional periods.
Content Errors: Errors in the data itself result in an "incorrect e-invoice." These cannot be fixed by simply referencing unstructured attachments.
Validation: Companies are encouraged to use validation applications to ensure compliance with "business rules" (completeness and consistency of mandatory fields).
3. Key Procedural Changes
No Consent Needed: Issuing e-invoices for low-value amounts, tickets, or to small businesses does not require the recipient's consent.
Attachments: Supplementary info (e.g., timesheets) must be embedded within the e-invoice file, not linked externally.
Contracts as Invoices: A contract only counts as an e-invoice if it meets the full semantic data model of EN 16931. Otherwise, a separate e-invoice must be issued to correct it.
Hybrid Formats: In ZUGFeRD-style files, if the human-readable PDF differs from the XML data, it may lead to additional tax liabilities under Sec. 14c UStG.
4. Storage (GoBD Updates)
As of July 2025, for e-invoices, it is generally sufficient to store only the structured data part. The human-readable part only needs to be archived if it contains additional tax-relevant information not present in the XML.
5. Status of the Document
This is currently a draft subject to change. The final version is expected in Q4 2025 and is intended to apply to all transactions carried out after December 31, 2024.