08.04.23

‘Growth Opportunity Act’, including e-invoicing delay

Germany’s April 2023 discussion paper had proposed a 1 January 2025 start date for the inception of the country’s B2B e-invoicing mandate.  

As is the case with other e-invoicing mandates however, mandate inception dates will always be subject to revision and influenced by externals factors- such as public readiness for the mandate, amongst others.  

Germany’s ‘Growth Opportunity Act’ has responded to the concerns raised in the public consultation regarding the inception date and has, for now, re-instated the mandate inception date to 1 January 2026. 

 In other important timeframes communicated:   

• E-invoicing will still be possible from 1 January 2025, although, in line with current regulations, recipient consent for e-invoicing will be required. However, paper, PDF and other invoice forms will still be permissible in 2025. 
• All structured e-invoice formats, including EDI, will be permitted up to 31 December 2027.  
• From 1 January 2028, structured formats must adhere to the EU common standard. 
• Presently, simplified invoices are expected to be precluded from Germany’s mandate. 

EDI has a robust following in Germany, particularly in the automotive and manufacturing industries. Adherence to the EU standard may accomplish harmonisation- but will be at odds with Germany’s powerful EDI following. It is inevitable that the question of the EU standard will come under scrutiny, especially given the proposed limitations post January 2028. 

It is important to note that the ‘Growth Opportunity Act’ is a draft bill only. Kofax is still waiting for the BMF to provide final technical specifications which will provide a definitive reflection of Germany’s mandate.