Business Central
Ina Rogalev
6. May 2026
On October 15, 2024, the Federal Ministry of Finance published a new letter regarding the introduction of mandatory electronic invoicing for transactions between domestic businesses from January 1, 2025.
In the letter with reference number “III C 2 – S 7287-a/23/10001 :007” and number “2024/0883282”, the BMF once again summarizes the changes that will apply from January 2025.
We have already listed the upcoming changes in detail in our blog series on this topic:
PART 1: What does the e-bill mean?
PART 2: Transitional rules and timetable for e-billing
PART 3: Format differences of the e-bill
PART 4: Requirements for the transfer of the e-bill
PART 5: The e-bill in practice
PART 6: Processing the e-invoice in Microsoft Dynamics 365 Business Central / Navision
PART 8: Permitted formats in Germany
In the following, we would like to address a few points that have repeatedly led to queries from our customers.
Recitals 5 and 6 of the BMF letter deal with the topics of origin, the integrity of the content and the legibility of the invoice.
An internal control procedure guarantees authenticity to the same extent as an electronic signature or a permissible EDP procedure.
An electronic signature is therefore not required.
This does not change the way in which it was previously ensured that an invoice was “genuine”.
Therefore, from January 2025, the “previous administrative interpretation required the characteristic “legibility”” will also change. Legible no longer means legible to the human eye, but machine-readable. (RN 31).
If the image part does not contain any invoice details that differ from the structured part, it is an identical multipart invoice. However, if the image part contains deviating information, it may constitute an additional (other) invoice. Minor deviations for technical reasons, or additional or supplementary information (e.g. a shortened description of services or rounding differences for reasons of presentation) are not objected to if the character of a multi-part invoice with identical content is not lost.
Important: Input tax deduction is also only possible from the structured part. (margin no. 32)
According to recital 17, the regulations on the mandatory use of e-invoices also apply to the issuing of invoices in the form of a credit note and to credit notes themselves.
It is important that the reference date 01.01.2025 refers to the performance period. An invoice dated 31.12.2024 can therefore also be issued after 01.01.2025 as a miscellaneous invoice.
The use of structured invoice formats that comply with the EN 16931 series of standards (see recitals 28 to 32) is always permissible. Likewise, structured electronic invoice formats that deviate from the EN 16931 series of standards can also be used under certain conditions, e.g. EDI procedures in accordance with Article 2 of Commission Recommendation 94/820/EC of October 19, 1994. According to recitals 33 and 34, EDIFACT invoices that are compatible with EN 16931, i.e. that transport the same content, can also continue to be used after the transitional periods.
The BMF defines that the use not limited to purely national formats such as XRechnung and ZUGfERD limited is not restricted.
The international formats such as Factur-X (France) or Peppol-BIS are permitted. The common denominator is the EN 16931 series of standards.
ATTENTION: The BMF nevertheless imposes one restriction:
If ZUGfERD is used, it must be a version from 2.0.1. The MINIMUM and BASIC-WL profiles are expressly excluded from ZUGfERD.
Important: The BMF explicitly refers in recital 27 to the fact that
“Which – permissible – format is used is a question of civil law that can only be decided between the contracting parties.”
For example, if my invoice recipient only accepts ZUGfERD, but as the invoice issuer I can only deliver X-invoices, I have to come to an agreement with my invoice recipient. Either he also allows the receipt of X-invoices or I deliver ZUGfERD.
One more note on Factur-x. ZUGfERD and Factur-x will be identical from September 18, 2024.
Options for transmitting e-invoices include sending them by e-mail, providing the data via an electronic interface, shared access to a central storage location or the option of downloading them via an Internet portal.
It is harmless if the file for an e-invoice is sent more than once, as long as it is the same invoice and the transmission only takes place as a multiple piece with identical content.
All you need to do is provide any e-mail inbox – it doesn’t have to be a dedicated one.
E-billing platforms will be important for the exchange of billing data as part of the reporting system to be introduced by law at a later date. The technically possible and legally permissible transmission channels will therefore have to be redefined as part of the reporting system.
If the invoice recipient refuses to accept an e-invoice or is technically unable to do so, they are not entitled to an alternative issue of another invoice by the invoice issuer.
According to recital 60, the structured part of an e-invoice must be stored in such a way that it is available in its original form and the requirements for immutability are met. It must be ensured that the tax authorities are able to analyze it automatically.
With regard to immutability, the BMF refers to the existing letters dated November 28, 2019, BStBl I p. 1269, para. 131 and 133 as well as the BMF letter dated November 28, 2019, BStBl I p. 1269, para. 130 et seq.
The previous timetable remains unchanged. The only new aspect is that EDIFACT invoices in accordance with Commission 94/820/EC of October 19, 1994 can continue to be used after the deadline.
MARKUS WEILAND
project manager
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