The new e-invoicing regulation
1. What is the new e-invoicing regulation for B2B transactions in Germany?
The new regulation requires all domestic B2B transactions in Germany to use electronic invoices that meet the EN16931 standard. This initiative is designed to increase transparency, improve tax processes, and align with the EU’s broader digital tax compliance goals.
2. When does the regulation come into effect, and what are the key deadlines?
The regulation will be phased in over several years:
From January 1, 2025: All businesses must be able to receive e-invoices in a structured format. Receiving invoices via email will be acceptable as long as they comply with the EN16931 standard. Traditional invoices, such as PDFs or paper invoices, will still be allowed.
From January 2027: Businesses with annual turnover over €800,000 must issue e-invoices that meet the standard.
By January 2028: All applicable businesses, regardless of turnover, must comply with the e-invoicing regulation.
3. Who is required to comply with this regulation?
The regulation applies to businesses legally based in Germany that issue invoices for domestic B2B transactions. This includes companies with a registered office, place of management, domicile, habitual residence, or a fixed establishment in Germany.
4. What is the EN16931 standard, and why does it matter?
EN16931 is a European standard for electronic invoicing that standardizes the format of invoices, ensuring they’re easily readable and processable across different systems. B2B invoices in Germany will need to follow this standard under the new regulation.
5. Are there any exemptions to this requirement?
Yes, invoices are exempt if they meet two criteria: (1) the invoice amount is less than EUR 250, and (2) the supplier is based outside Germany. This exemption provides flexibility for small-value or foreign-sourced transactions.
6. Does the new regulation apply to transactions involving foreign suppliers?
No, the upcoming German e-invoicing regulation does not apply to transactions from foreign suppliers. It only mandates structured e-invoices for domestic B2B transactions involving entities established in Germany. Foreign suppliers are exempt unless otherwise agreed with German partners.
7. Does the e-invoicing regulation apply to B2B transactions settled via card payments?
Yes, the e-invoicing mandate applies regardless of whether the payment is made via credit or debit card. The obligation to issue an electronic invoice is determined by the nature of the B2B transaction and not influenced by the method of payment.
Practical implications and preparation
8. Will paper or PDF invoices still be accepted?
No, neither paper nor simple PDF invoices will meet the new requirements for domestic B2B transactions. Invoices will need to be in a structured electronic format that complies with EN16931. PDFs will only be acceptable if they’re accompanied by structured data required by the standard, phasing out traditional PDF and paper invoice processing.
9. What benefits will the e-invoicing regulation bring to my business?
This regulation aims to simplify and automate invoicing, reducing manual data entry and increasing transparency around cash flow. It should also speed up processing times and reduce the risk of errors or disputes over invoicing.
10. How should my business prepare for this regulation?
To get ready, businesses should:
Update internal systems to ensure all invoices for German customers are issued electronically.
Implement a solution that enables processing of e-invoices received from suppliers.
Train your Finance team on the requirements and importance of compliance.
Moss to the rescue
11. Do I need to take any action for Moss to support e-invoices, and when will it be available?
Once Moss launches e-invoicing support (expected early December), no additional action is needed. Customers with access to our Corporate Cards and Accounts Payable modules will automatically be able to process e-invoices through Moss and verify compliance with the new e-invoicing regulation.
12. What e-invoice formats are supported by Moss?
Moss supports both XRechnung and ZUGFeRD formats, which are compliant with EN16931 and fulfill the new requirements.
XRechnung: A structured XML file that’s commonly used in Germany and designed for compliance with national standards.
ZUGFeRD: A hybrid format that combines PDF/A-3 with embedded XML data, making it both human-readable and machine-readable.
13. How does Moss help ensure compliance with the new e-invoicing regulation?
Moss automatically validates invoices against the EN16931 standard and classifies them as “Compliant,” “Not Compliant,” or “Exempt.” Invoices marked as “Not Compliant” may need adjustments before acceptance. Moss also flags any invoices that don’t meet the standard or identifies them as exempt if applicable, helping businesses maintain smooth operations while staying compliant.
14. How do I process e-invoices with Moss from beginning to end?
Capture e-invoices via your Accounts Payable inbox or upload them manually. Note: E-invoices can be processed through the existing Document inboxes alongside traditional invoices, ensuring compliance with German regulations.
Automatically read the data and populate all relevant invoice details.
Validate e-invoices for compliance with the EN 16931 standard.
Define accounting dimensions to ensure accurate categorization.
Route e-invoices through your established approval process to ensure financial control.
Initiate payment for approved invoices, maintaining visibility and control over payment status.
Export finalized e-invoices to your accounting system to support reconciliation and reporting.
Archive the original e-invoice file for secure record-keeping and easy retrieval.
15. Can I set specific suppliers as exempt from the e-invoicing requirement in Moss?
Yes, Moss allows you to manage the transition smoothly by defining specific suppliers who are exempt from providing e-invoices. This flexibility is especially helpful, as traditional invoices will still be permitted until January 2027. By setting supplier exemptions, you can ensure compliance while accommodating suppliers who may not yet be ready to adopt the new e-invoicing formats.