Germany’s mandate inception date has always been subject to revision, fluctuating between a suggested 2025 or 2026 start date. The divisions regarding the country’s B2B e-invoicing commencement date are now starting to become more visible.

Last month, Kofax communicated that the German Ministry of Finance, the BMF, were presenting some further information to the German Parliament, proposing that German businesses possess the capability to receive e-invoices from 1 January 2025.

Germany’s current proposed timeline, in line with the current Tax Bill, is expected to follow the following trajectory:

• January 2025: E-invoicing (pertaining to e-invoice exchange between suppliers and buyers) is optional.
• January 2026: Taxpayers with an annual turnover exceeding 800,000 Euros must adhere to e-invoicing obligations.
• 1 January 2027: E-invoicing obligations extend to small businesses.

In a marked contrast, the German Bundesrat is proposing to delay e-invoicing for all business yet further, to January 2027. The Bundersat is a different institutional body to the BMF; it represents all German Federal States on a legislative level, and it will be tasked with reviewing the e-invoicing law by the end of the year.

The German Bundersat overwhelmingly supports the e-invoicing initiative, but, in addition to the timeframes, holds some concerns around the process, particularly relating to the admissibility of specific invoice formats and adherence to a common e-invoicing standard. Furthermore, representing states on Federal level, the Bundersat will be acutely aware of the need for all 16 states to adjust to the e-invoicing regulations.

Further information on the Bundersat’s e-invoicing reasoning can be accessed below:

https://www.bundesrat.de/SharedDocs/drucksachen/2023/0401-0500/433-23(B).pdf;jsessionid=5417585DF8CB195A7F7194E1E4A0096C.live542?__blob=publicationFile&v=1

Germany is a significant and compliant territory for Kofax, and the confirmation of Germany’s e-invoicing mandate inception will be critical for Kofax to commence its e-invoicing strategy in Germany. Kofax is closely monitoring progress in respect of the start date, as well as more defined details around Germany’s e-invoicing model.