Update to Growth Opportunities Act - Transition period for e-invoicing extended

Compared to the draft bill of the Federal Ministry of Finance (as we reported here), this  version includes an important change regarding the transition rules for e-invoicing.

E-invoicing will be mandatory for certain transactions starting 1 January 2025. According to the current status of the legislative process, the following changes have been introduced to ease the transition:

• For transactions between 1 January 2025 and 31 December 2025, an "other invoice" can be issued instead of an e-invoice until 31 December 2025 – as a paper invoice or, with the recipient's consent, in another electronic format.
• Entrepreneurs whose total turnover according to § 19 (3) of the UStG (German VAT Code) in the previous calendar year did not exceed € 800,000 may continue to apply this simplification rule for one additional year, i.e., until 31 December 2026 for turnover between 1 January and 31 December 2026.
• For transactions between 1 January 2026 and 31 December 2027, an "other invoice" may be issued instead of an e-invoice until 31 December 2027 if transmitted via EDI and the recipient consents.

Dated: 8 September 2023

Author

Nadia Schulte
+49 211 83 99 330