electronic invoicing

From January 1, 2025, electronic invoicing will become mandatory in the B2B sector in Germany. This will also bring about significant changes for companies in the energy industry.

Legal basis and definition of electronic invoices
The obligation to use electronic invoicing is based on the Growth Opportunities Act. Among other things, the aim of the regulation is to increase the digitization of accounting and to introduce an electronic reporting system to combat VAT fraud more efficiently. An electronic invoice within the meaning of the law is an invoice that is issued, transmitted, and received in a structured electronic format and enables automatic electronic processing. This format must comply with the European standard for electronic invoicing – specifically the CEN standard EN 16931. Common formats for this are XRechnung and ZUGFeRD. It should be noted that a PDF file simply sent by email does not qualify as an electronic invoice within the meaning of the law, as it cannot be processed automatically.
 
Affected companies and transition periods
The obligation to issue electronic invoices applies to all companies based in Germany that provide services to other companies, i.e., the entire B2B sector. Both the service provider and the service recipient must have their registered office, management, or a permanent establishment in Germany.
 
Transition periods have been set to facilitate the transition:

• Until the end of 2026, companies may continue to issue and send paper invoices. Electronic invoices that do not comply with the new format are also permitted during this period, provided the recipient agrees.
• Until the end of 2027, this option will apply to companies with a previous year's turnover of up to €800,000. Larger companies must switch completely to the structured electronic format from 2027.
• From 2028, only electronic invoices in the prescribed format will be permitted. Input tax deduction will then only be possible with such invoices.

In the energy industry, there are specific variants of these formats that are maintained and further developed by the edna Federal Association for Energy Market & Communication in order to meet the special requirements of the industry.
 
Challenges in implementation
The introduction of electronic invoicing brings with it various challenges. One of the biggest is dealing with version changes in invoice formats. Both XRechnung and ZUGFeRD are updated regularly, forcing companies to continuously adapt their systems and processes. This requires not only technical expertise, but also resources for implementation and employee training.
 
Another problem is ensuring compatibility between different systems and formats. Companies must ensure that their electronic invoices can be processed by their business partners' systems. This can lead to difficulties, especially for companies with complex IT infrastructures.
 
Companies must not only be able to send electronic invoices. It is also important that they are able to receive and process them. From January 1, 2025, they will be required to set up appropriate systems. For input tax deduction, it is crucial that the invoices received comply with legal requirements. From 2028, input tax deduction will only be possible with electronic invoices in the prescribed format. This means that companies without appropriate systems could suffer tax disadvantages.
 
Outlook and recommendations
The introduction of electronic invoicing is not only a legal obligation, but also offers opportunities for greater efficiency and transparency in business processes. Companies should use the transition periods to prepare for the new requirements at an early stage. This includes analyzing existing systems, selecting suitable software solutions, and training employees.
 
Thorough preparation is essential, particularly in the energy industry, which is characterized by specific requirements and complex billing models. Companies should examine which formats are best suited to them and how they can ensure compatibility with their business partners.
 
Solutions from AKTIF
AKTIF offers comprehensive solutions and expertise for implementing mandatory e-invoicing. We support companies in both electronic invoicing and receiving corresponding invoices – and we already do so for many customers today. Some of the processes required for this have been in productive use for some time and include the implementation of XRechnung and ZUGFeRD, adaptation in the context of version changes, and integration into existing systems. With the help of our software and/or customized services, AKTIF helps you meet legal requirements while increasing the efficiency of your business processes.