B2B E-Invoicing in Germany: What Changes in 2025?

In the final quarter of last year, the German government released finalized B2B e-invoicing guidelines and published a draft letter introducing several necessary clarifications and amendments. 

Following the publication of those documents and the implementation of mandatory B2B e-invoicing on January 1, 2025, the Ministry of Finance issued a second draft letter on June 25, 2025, amending the VAT Implementation Decree (UStAE) and providing additional guidance on e-invoicing rules and regulations.

Key Clarifications Provided by the Ministry of Finance

E-invoices must follow strictly defined rules for formatting and content requirements to be considered compliant. Otherwise, they will be categorized as non-compliant documents or simply as “other invoice”, which may impact their legal and tax validity. Additionally, Content-related errors, such as missing mandatory information, will also render the e-invoice invalid, even if the missing details are found in attached documents.

Furthermore, if the previous e-invoice is correct, the new invoice must follow the same format. The Ministry of Finance recommended that taxable persons use validation tools that verify conformity with European Norm (EN) 16931, the standard governing e-invoicing in the EU, to meet these requirements.

The Ministry of Finance underlined that e-invoices are not required for specific categories, such as low-value invoices under € 250, travel tickets, or invoices issued by small businesses. However, even in these cases, e-invoices can still be issued for B2B transactions without the recipient's prior consent. In contrast, for B2C transactions, businesses must obtain the recipient's consent before issuing an e-invoice.

Regarding record-keeping, the structured part of an e-invoice must be preserved in its original format for eight years. The use of a system that guarantees the document’s authenticity, integrity, and readability is mandatory. Potential solutions to ensure authenticity, integrity, and readability include conducting internal controls, utilizing electronic signatures, or implementing Electronic Data Interchange (EDI) systems.

Conclusion

The second draft letter is now open for public consultation, allowing all industry stakeholders to provide feedback on the proposed changes. The final version of the second letter is expected in the final months of 2025. If enacted, the rules are expected to apply from January 1, 2025, retroactively. However, taxable persons subject to these e-invoicing should carefully review the proposed measures and determine if their systems meet all the requirements.

Source: Federal Ministry of Finance, VATabout