At the end of March of this year, the German government approved the Growth Opportunities Act, which introduced several new tax measures, including new regulations for electronic invoicing in Germany.
Accounts Payable teams in enterprises which operate in Germany should be aware of the regulations around receiving, processing, and archiving German electronic invoices.
JAGGAER Invoicing allows Accounts Payable teams to receive and process supplier invoices, and therefore this article will focus on the impacts to Accounts Payable processes.
Because purchasing professionals are mostly concerned with receiving invoices and processing them for payment, JAGGAER’s focus, and this blog post, is mostly centered about the reception of invoices, not their issuance.
The new German mandate is not a Clearance model
Unlike Italy, which uses a central clearance house called the SdI, or France in the future, where the government or a group of authorized companies (called PDPs) will review and authorize every single transaction, the German e-invoicing B2B model, up until today, is not planned to have a centralized node reviewing and / or authorizing every single invoice.
Taxpayers will still send invoices to each other.
How soon do I need to be ready to receive invoices according to the new legislation?
Time has become of essence on this subject because the Growth Opportunities Act has established that all buyers entities resident in Germany, for the purposes of domestic B2B transactions, will have to be ready to receive electronic invoices compliant with the European standard EN 16931 starting from January 2025.
Some information about old and new formats
Paper invoices will remain valid throughout 2025, but any electronic format not compliant with the EN 16931 standard will require the buyer’s consent, while EN 16931 formats will not. It is therefore expected that consent – free formats will become more popular than the ones that need consent.
For a clear visual understanding of the timeline established by the German government, refer to the chart below.
The XRechnung standard, which has been around for a while and it is widely used in Germany for B2G invoices, is compliant with the EN 16931 standard, and will most likely be embraced by German Suppliers to issue B2B invoices in light of the new legislation.
Another popular format in Germany is ZUGFeRD, which is a hybrid format in the form of a PDF/A-3 file containing an embedded XML. Most likely, the ZUGFeRD standard will also be broadly used or adopted.
Both formats have advantages and disadvantages which we will explore on future entries.
While it would seem that the legislation calls for the elimination of the EDI formats, it appears impossible that this whole industry could be eradicated in Germany, given its decades long relevance in certain sectors of the economy. Rather, it seems that the EDI formats, if not compatible already with the EN 16931 standard, will need to find a way to become compatible, or a way to easily extract and convert information, perhaps in the form of reports, will need to be implemented before 2028.
Different invoicing methods, explained on a timeline
When looking at the timeline legislated it becomes evident that the government has created a phased approach where the structured formats based in EN 16931 become immediately mandatory for reception of invoices while the reception of other formats (unstructured and paper) are slowly deprecated.
Regarding delivery
Up until now the German government has not mandated on a delivery channel, leaving this at the liberty of taxpayers.
That means that a simple channel, like email or a file upload or transfer, could be enough.
Of course, the market is free to implement more sophisticated delivery channels that could provide additional advantages like security, traceability, etc. such as PEPPOL.
JAGGAER coverage
JAGGAER will support the reception of the XRechnung and ZUGFeRD formats in accordance to the Growth Opportunities Act on behalf of our customers by the end of 2024.
