Germany’s B2B electronic invoicing law approved
This article was last updated on January 6, 2026, to reflect the introduction of the German Electronic Business Address (GEBA) for the Peppol network.
Summary
B2B electronic invoicing rules in Germany were introduced on January 1, 2025. However, a transitional period is currently in place, leveraging what are known as "Übergangsregelungen" (transitional rules).
An electronic invoice (E-Rechnung) must be issued, transmitted, and received in a structured electronic format that allows automatic processing and correct extraction of VAT-relevant data according to EN 16931.
The implementation of Germany’s mandatory B2B e-invoicing follows a phased schedule, distinguishing between the obligation to receive invoices (already active) and the obligation to issue them (future phases).
EDI formats are allowed, provided they enable the correct and complete extraction of VAT-relevant data in accordance with the EN 16931 standard (or another interoperable structured format).
Germany has Business-to-Government (B2G) e-invoicing mandates in place.
The Growth Opportunities Act
On November 17, 2023, the Growth Opportunities Act (Wachstumschancengesetz), including the compulsory Business-to-Business (B2B) electronic invoicing regulation, was approved by the German Bundestag. The Act underwent several amendments compared to the initially submitted version.
In its session on February 21, 2024, the German Mediation Council revisited the Growth Opportunities Act. The B2B e-invoicing mandate remained largely unchanged, with previous timelines remaining valid. Good news arrived on March 22, 2024, when the Bundesrat approved the Growth Opportunities Act with a clear majority.
This final approval solidifies the B2B electronic invoicing mandate, ensuring its implementation in accordance with the previously established timelines.
Germany’s latest VAT and e-invoicing proposals
Current definition of an electronic invoice
Recent legislative decisions have confirmed the definition of an electronic invoice and the classification of paper invoices under the mandatory e-invoicing rules.
Germany’s electronic invoicing rules for B2B transactions have been in effect since January 1, 2025, though a phase-in period utilising so-called “Übergangsregelungen” (transitional rules) allows for the continued use of paper invoices and “non-compliant” electronic invoices (with recipient consent) until December 31, 2026.
The transitional rules period notwithstanding, an electronic invoice (E-Rechnung) must be issued, transmitted, and received in a structured electronic format that allows automatic processing and correct extraction of VAT-relevant data according to EN 16931 (or another mutually agreed structured format). This includes formats such as XRechnung (the official German B2G standard) and ZUGFeRD (a popular hybrid format). You can read more about these formats here.
Simple PDF documents or paper invoices will no longer qualify as electronic invoices and will instead be classified as “other invoices” (sonstige Rechnungen).
New mandatory e-invoicing dates and procedures
The following mandatory dates and procedures apply to all Business-to-Business (B2B) invoicing scenarios:
Since January 1, 2025: All domestic B2B companies must be able to receive structured e-invoices compliant with EN 16931. Buyer consent is no longer required for sending e-invoices, provided the invoice is issued in a structured format.
Until December 31, 2026: Paper invoices and e-invoices in formats that do not comply with EN16931 are still allowed, but may only be sent with the consent of the recipient.
From January 1, 2027: B2B e-invoicing issuance obligation for businesses with a previous year's (2026) turnover of EUR 800,000 or more. Businesses are allowed to continue using EDI.
From January 1, 2028: B2B e-invoicing issuance obligation for all businesses. EDI is still permitted, provided that the VAT information can be extracted in EN16931.
The status of EDI
The status of EDI has been clarified: EDI remains permitted for B2B electronic invoicing as long as the chosen format enables the correct and complete extraction of VAT-relevant data in line with EN 16931 (or another mutually agreed structured format). No further legislative vote is required.
The German Electronic Business Address (GEBA) and Peppol
While the obligation for all B2B companies to receive structured e-invoices compliant with EN 16931 has been active since January 1, 2025, Germany has created an additional infrastructure to significantly simplify the technical handling of sending and receiving: the German Electronic Business Address (GEBA).
Foundation: GEBA is a standardized electronic identifier for companies and their sub-units within the Peppol network, built upon the national business identification number (Wirtschafts-Identifikationsnummer, or short W-IdNr), which is being issued by the Federal Central Tax Office (BZSt) since late 2024. For companies with a VAT ID, the W-IdNr is identical.
Structure: A GEBA address can contain up to three components, allowing for precise routing within complex organizations: the Core W-IdNr (mandatory), an optional Distinguishing Feature (for different business locations), and an optional Sub-addressing suffix (for internal departments like Purchasing or Accounting).
Routing: It allows complex internal company structures to be precisely mapped in the Peppol network, improving the routing of e-invoices to the correct department (e.g., purchasing, accounting).
Status: The use of GEBA is entirely voluntary and acts as an infrastructure layer to improve document routing and interoperability, not a new bureaucratic hurdle. It coexists with other addressing systems like GLN or Leitweg-ID.
Technical integration: GEBA is registered for Peppol under the international identification scheme ISO/IEC 6523 Code “0246”. Its official specification was published by KoSIT's XStandards Einkauf (XSE) in December 2025 and was subsequently added to the Peppol identifier scheme code list starting with v9.5 (from Dec 23, 2025).
GEBA is seen by commentators as a foundational building block for potential future developments in German e-reporting, such as a 5-corner model that could eventually integrate tax authorities, positioning Germany for tighter digital VAT controls.
Germany’s e-invoicing history
Germany, like many European Member States, currently has Business-to-Government (B2G) e-invoicing mandates in place. All public bodies must be able to receive electronic invoices, and all public body suppliers must send electronic invoices to their government contractor.
The first inclination of Germany’s intentions to mandate B2B electronic invoicing was on June 23, 2023, when the European Commission gave the country permission to move away from certain parts of the European VAT directive.
Germany’s plan aligns with the VAT in the Digital Age directive, which is also persuading many European Member States to address their e-invoicing regulation intentions.
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Danielle Kiener
Lead Key Account Manager, Banqup Group
Danielle has 15 years of experience in customer relationship management within invoicing and financial administration. She currently works in Geneva, supporting global customers at Banqup Group and helping multinational companies digitise their processes. Over the years, she has been closely involved in the digital transformation of invoicing, including leading e-invoicing initiatives across the EMEA and Asia-Pacific regions for a major multinational. Her extensive experience means she’s always up to date on the latest e-invoicing regulations and changes around the world.
