Key takeaways
- Germany confirms 2025 e-invoicing mandate: Final guidelines clarify accepted formats (excluding ZUGFeRD MINIMUM/BASIC-WL, adding Peppol BIS) and strengthen rules on security, signatures, and data transmission.
- Focus on compliance and interoperability: Businesses must align internal systems and contracts with new format, transmission, and verification standards under Germany’s Growth Opportunities Act.
- France faces possible delay: Technical setbacks in the rollout of its e-invoicing infrastructure suggest that mandatory B2B e-invoicing may not launch on schedule.
In short: On October 15, 2024, Germany released final guidelines for mandatory e-invoicing for domestic businesses, starting January 1, 2025. They drop two ZUGFeRD profiles and approve Peppol BIS Billing. On the same day, France signaled that its B2B e-invoicing rollout was off schedule, with a new focus on private platforms (PDPs).
Update (October 2026): In Germany, all businesses have had to be able to receive e-invoices since January 1, 2025. The duty to issue them is phased in until January 1, 2028. France's B2B e-invoicing mandate took effect on September 1, 2026, and the approved private platforms are now called "plateformes agréées".
What do Germany's final e-invoicing guidelines say?
Germany's final e-invoicing guidelines set out how mandatory electronic invoicing works for domestic businesses from January 1, 2025. The German Ministry of Finance released them on October 15, 2024.
This official version refines the June draft. It clarifies key parts of the Growth Opportunities Act (Wachstumschancengesetz). It also supports Germany’s move toward fully digital invoicing.
How do the new guidelines affect e-invoicing in Germany?
The new German guidelines confirm which formats count, how to check a buyer's status, and how to send e-invoices. They include the following clarifications and updates:
- Exclusion of certain formats: ZUGFeRD profiles MINIMUM and BASIC-WL do not meet EN 16931. So they are not allowed as e-invoice formats.
- New format inclusion: Peppol BIS Billing is now an approved e-invoice format. This gives you more ways to comply.
- VAT ID use for domestic status: Invoice issuers may use a buyer's VAT ID to decide if the buyer is a domestic business. This does not apply when other information contradicts it.
- Applicability to mixed tax services: The e-invoicing duty also covers deals with both taxable and tax-exempt parts (e.g., those under Section 4 (8) to (29) UStG).
- Enhanced security measures: The guidelines give more detail on qualified electronic signatures, EDI procedures, and internal control systems. These help prove that invoices are authentic and unchanged.
- Civil law agreement emphasis: There is a stronger focus on trading parties agreeing on the e-invoice format and sending method under civil law.
- Transmission Methods: The guidelines list ways to send e-invoices, including email, electronic interfaces, shared storage, and internet portals.
- Role of E-Invoicing Platforms: E-invoicing platforms will be central to real-time data reporting. However, the timeline for this reporting duty is still pending.
These updates show how e-invoicing rules keep changing. They put the focus on compliance, security, and flexible formats and sending methods.
Will France's e-invoicing mandate be delayed?
France's e-invoicing mandate faced possible further delays in October 2024. The mandatory B2B e-invoicing rollout is a core part of France's tax compliance and digital strategy.
A government press release on October 15, 2024, signaled that the project was off schedule. It shifted focus to two key parts: a recipient directory (annuaire des destinataires) and a data concentrator (concentrateur des données).
What does this mean for businesses?
For businesses, the new priorities raised doubts about whether the needed infrastructure would be ready on time. This hinted at possible delays. As a result, businesses began to question whether the original timeline could still be met.
Key points from the press release include:
- Role of PDPs:
The press release stresses the key role of PDPs (plateformes de dématérialisation partenaires, or partner platforms). It expresses confidence that they can deliver high-quality, secure services that meet businesses' varied needs. - Responsibilities of PDPs:
PDPs handle issuing, receiving, and sending e-invoices. They make sure everything complies with the new rules.
This announcement, however, raises an important question:
- Implications for the Public Invoicing Portal (PPF):
This shift suggests the Public Invoicing Portal (PPF) may no longer handle the duties set out in Article 242-G. The release does not say this directly. But some industry experts read it as a possible move of these duties to PDPs.
Key dates
Germany
- January 1, 2025: All domestic businesses must be able to receive e-invoices.
- December 31, 2026: End of the general transition period. Until then, paper invoices and other electronic formats, such as PDF, remain allowed.
- December 31, 2027: End of the extra transition year for businesses with prior-year turnover of up to €800,000, and for EDI invoices.
- January 1, 2028: All businesses must issue e-invoices that meet EN 16931 for domestic B2B sales.
France
- September 1, 2026: All companies must be able to receive e-invoices. Large and intermediate-sized companies must also issue all their invoices electronically.
- September 1, 2027: Small and micro-enterprises, including auto-entrepreneurs, must issue e-invoices.
What should businesses do now?
In Germany, check that your invoicing system can receive and read EN 16931 formats. Plan the switch to issuing e-invoices before your transition period ends. Remember that the ZUGFeRD MINIMUM and BASIC-WL profiles do not count as e-invoices.
In France, every company needs a plateforme agréée, a private provider registered by the State, to issue and receive e-invoices. Sales to private individuals and cross-border sales fall under e-reporting instead. Here, transaction data is sent to the tax authority, as explained on impots.gouv.fr.
For French VAT rates and registration rules, see our France VAT guide.
How Taxually handles this
Taxually’s e-invoicing API sends structured invoices to each country’s clearance platform, such as Italy’s SDI, Poland’s KSeF and Peppol networks, covering 32 countries from one integration. The VAT returns those invoices feed into are filed through CrossTax on the same platform.
Related guides
Frequently asked questions
When does Germany’s e-invoicing mandate take effect?
Germany’s mandatory e-invoicing for domestic B2B transactions begins on January 1, 2025, under the Growth Opportunities Act (Wachstumschancengesetz). From that date, all businesses must be able to receive e-invoices. The duty to issue them is phased in, and applies to all businesses from January 1, 2028.
Which e-invoice formats are accepted in Germany?
Peppol BIS Billing is now an approved format, while ZUGFeRD MINIMUM and BASIC-WL profiles are excluded for non-compliance with EN 16931.
How will invoices be transmitted under the new rules?
E-invoices may be exchanged via email, electronic interfaces, shared platforms, or portals, provided they meet authenticity and integrity requirements.
What’s happening with France’s e-invoicing rollout?
In October 2024, France’s B2B e-invoicing launch faced possible delays as the government shifted focus to its recipient directory and data concentrator infrastructure. The mandate took effect on September 1, 2026.
When must French businesses issue e-invoices?
Large and intermediate-sized companies must issue e-invoices from September 1, 2026. Small and micro-enterprises have until September 1, 2027. All companies must be able to receive e-invoices from September 1, 2026.
