The first phase of the e-invoicing requirement will begin for companies in 2025 – but business associations are very concerned that smaller companies in particular will not be able to keep up. “In our opinion, a general, mandatory willingness to receive e-invoices at the beginning of 2025 is not feasible, especially as long as no state e-invoice tool is available,” said Jens Profitus, tax expert at the German Chamber of Commerce and Industry (DIHK) at iX -Editorial staff.
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The Central Association of Handicrafts (ZDH) is also bothered by the deadline for the obligation to receive and is also insisting on a software solution from the state. The ZDH refers to the protocol for the resolution of the Growth Opportunities Act, in which the Bundestag calls on the federal government to make appropriate software available to all companies by January 1, 2025. When asked by the iX editorial team, the Federal Ministry of Finance stated that it was still examining the form in which such an offer could be made available.
Standard is being revised
The law stipulates that all companies doing business within Germany must accept structured e-invoices in three formats from 2025. The formats are the two XML formats Cross Industry Invoice (CII) and Universal Business Language (UBL) as well as the hybrid format Factur-X/ZUGFeRD. From 2027 onwards, companies will be required to send invoices in this format on a staggered basis. By 2028 at the latest, small companies will only be allowed to send electronic invoices to their business partners. The obligation only applies to invoices between companies, the so-called B2B area, in Germany. Invoices to private customers or abroad are not affected.
It is also problematic that the authority accounting standard EN16931 is currently being revised at the EU level, explained Profitus from the DIHK. This results in the XML formats CII and UBL of an e-invoice. In Profitu's estimation, it may take until at least the second half of next year before the changes are implemented in software. “As of January 1, 2025, there will be no practical e-invoicing software available for B2B invoice exchange,” he concluded. There is also the time for implementation at companies and software service providers. Companies should therefore be given at least one more year, demands the DIHK.
Eight percent still issue paper invoices
The IT industry association Bitkom, which is fundamentally inclined towards digital things, also points to the opportunities of electronic invoice exchange, which holds considerable potential in the medium and long term. But the effort involved in switching to structured formats should not be underestimated, explained Bitkom speaker Daniil Heinze. According to a survey by the association last year, small companies in particular are lagging behind: structured e-invoicing standards such as EDI, ZUGFeRD or Percent. At the same time, by 2023, eight percent of companies in Germany would have only created invoices in paper form.
The Association of Founders and Self-employed People in Germany also pointed out the difficulty for small businesses and solo self-employed people. The latter in particular often still used Word or Excel for invoicing, explained association board member Andreas Lutz. He appealed to those affected to change their invoicing and accounting as soon as possible. “Once introduced, digital processes offer long-term advantages if you do it wisely,” said Lutz. There's no getting around the change anyway.
The HDE trade association pointed out that other EU states such as France, which started introducing mandatory electronic invoices earlier than Germany, have also often pushed back the start dates. If the time frame turns out to be too short, Germany should do the same, said Ralph Brügelmann, tax expert at the association. Just like all the business associations that the iX editorial team interviewed, the HDE is also sure that e-invoicing can simplify a lot of things and will ensure efficiency gains through automation in the medium to long term. But in the short term, there is probably a problem in Germany.
Note on our own behalf: The heise Academy's workshop “E-invoicing obligation: implementing software correctly” explains the new legal requirements for the domestic e-invoicing obligation that companies must meet from 2025.
(sigh)