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BMF eliminates PDF and paper invoices
for (almost) all B2B transactions

A few days ago, the Federal Ministry of Finance (BMF) presented a draft for the so-called "Growth Opportunities Act" to selected institutions, associations as well as several TRAFFIQX-providers for feedback. So far, so boring. But what at first sounds like rather bland "political talk" for the parliamentary summer recess in Berlin has a lot going for it - especially regarding the exchange of invoices between companies in Germany.

The "Draft Law for Strengthening Growth Opportunities, Investments and Innovation as well as Tax Simplification and Tax Fairness" (Growth Opportunities Act) contains a whole series of groundbreaking proposals - not only for the digital "developing country" Germany - for changing the traditional way in which companies still exchange invoices today. Or rather: according to the current view of the tax authorities, they should! 

Probably the most far-reaching change:

PDF and paper invoices between companies will be banned !
 In less than 30 months!

The (TRAFFIQX wording) draft bill is part of the Federal Ministry's efforts to strengthen growth opportunities in the German economy, to promote investment in Germany as a business location, to support innovation and the digital transformation, and to make the tax system fundamentally both simpler and fairer. The implementation of the "Growth Opportunities Act" now presented is thus also in line with the EU's ViDA initiative and the increasing use of CTC (Continuous Transaction Control) models to successfully combat large-scale VAT fraud everywhere in other European countries.

However, not wanting to be left behind digitally, the, the Federal Ministry of Education and Research has put together a whole series of measures to make the largest economy in the European Union digitally fit for the future (and thus significantly more attractive for companies).

In addition to numerous other sectors, the catalog of measures from the nearly 280-page Growth Opportunities Bill includes five far-reaching changes for B2B invoice exchange - whether digital or (still) paper-based:

    1. Mandatory e-invoice: From January 1, 2025, all B2B receivers must not only be able to receive e-invoices in accordance with the requirements of EU Directive 2014/55/EU, but also to archive them electronically (and ideally also downstream process them digitally). However, it is not possible to reject an electronically transmitted data set that complies with the EU standard EN16931.

    2. Only a few exceptions: The obligations do not apply to invoices under 250 Euros and tickets.

    3. End of the paper invoice: The paper invoice will already lose its precedence over the eInvoice from 2025, which will become the new "best practice". The receiver's consent to receive electronic invoices in accordance with the above-mentioned EU Directive will no longer be mandatory - instead, delivery in all "other" formats such as PDF or other digital formats such as EDI/EDIFACT will only be possible with the consent of the receiver or recipient. Only the paper invoice remains unaffected by this.

    4. Transition period for "other" invoice formats: Until the end of 2025, other digital invoice formats are also permitted, provided the recipient agrees. From 2026, "normal" PDF and paper invoices are no longer permitted. For all those "other" digital formats, however, there is still a final "reprieve" until the end of 2027. After that, only electronic B2B invoices in EU-compliant formats such as (currently) XRechnung or ZUGFeRD 2.X are permitted.

    5. Possible "special treatment" for EDI: From the current draft bill, a certain protection of the status quo, which was also discussed animatedly with the BMF representatives present at this year's e-invoice summit, can be derived for the EDI process, which is particularly widespread in industry - at least for the next three and a half years.

    However, it remains unclear for the time being what will happen to EU-compliant invoice data formats via EDI (possibly by the deadline). For the time being, it remains unclear which transmission channels will ultimately be permitted to implement the planned digital VAT reporting system based on electronic invoice exchange in Germany from 2028. The draft merely refers to the "introduction of the reporting system" and thus presumably deliberately leaves some room for maneuver and discretion for a later specification. 

    It already seems clear today, however, that as soon as the second "expansion stage" of the planned electronic reporting system is launched in Germany, it will no longer be sufficient to simply send EU-compliant eInvoice formats WITHOUT a corresponding platform connection. In other words: By the end of 2027 at the latest, every company in Germany must be connected to a government or private eInvoicing platform. 

    BMF pushes the timetable

    After the scheduled hearings and votes in the Bundestag and Bundesrat, publication of the law is expected as early as the beginning of 2024. No wonder, because time is indeed pressing if the self-proclaimed digitization coalition of SPD, FDP and Bündnis 90/Die Grünen wants to implement the goals it has set itself for implementing a digital reporting system in Germany in good time before the Europe-wide deadline of January 1, 2028 - and thus become the master of the presumed double-digit billions of euros in unpaid sales tax that have so far passed the treasury year after year.

    No matter what formats and transmission paths are required in the future for the tax- and legally compliant fast, environmentally friendly and secure exchange of invoice data: With the TRAFFIQX network, you as sender and receiver are always on the safe side.