News from Berlin

BMF wants legal and planning security for EDI, XInvoice and ZUGFerD


On October 2, 2023, the BMF published clarifications, in particular on format issues, as part of the consultation with associations on the Wachstumschancengesetz (WTChancenG).

First of all, the BMF states that an invoice according to the XStandard as well as according to the ZUGFeRD format as of version 2.0.1 basically represents an invoice in a structured electronic format that complies with the European standard for electronic invoicing and the list of corresponding syntaxes. Invoices in these formats are to comply with the new VAT requirements even after December 31, 2024, provided that the legislator retains the corresponding wording in the government draft of the WTChancenG. To this end, it is noted that in the case of a hybrid invoice format, which is regularly composed of an image file and a data file, the structured part is considered to be leading.

Furthermore, the criticism voiced by IDSt regarding the threatened “abolition” of the EDI procedure is also having an effect. The Federal Ministry of Finance is aware of the importance of EDI for certain sectors of the economy and states that it is currently working on a solution that will ensure the continued use of EDI as far as possible in the future. As IDSt, we very much welcome this development. Thank you for the commitment of the Expert Committee III chaired by Jan Körner!

Finally, the BMF clarifies that the staggered introduction of e-invoicing on January 1, 2025 and January 1, 2026, respectively, exclusively concerns the issuance of electronic invoices. The obligation to accept them, on the other hand, is uniform for all domestic entrepreneurs. In accordance with the government draft of the WTChancenG, January 1, 2025 applies here.

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