Regulatory updates - Germany

On April 1, 2025, the Rhineland-Pfalz E-Invoicing Ordinance RLP 2025 (E-Rechnungsverordnung RLP, ERechVORP) came into effect, mandating electronic invoicing to public entities in the state. This regulation outlines the requirements of the federal E-Invoicing Act, forming part of the implementation of Directive 2014/55/EU on electronic invoicing.

Rheinland-Pfalz

Invoice issuers can submit e-invoices via email, the state's portal, or the Peppol network. Independent of submission methods, businesses first must register on the portal.

The required formats are XRechnung or ZUGFeRD. It is specified that only the XML file of ZUGFeRD hybrid invoices will be processed and sent to the invoice recipient, while the PDF files will be discarded.

More details on how to submit an e-invoice and routing IDs are available here (in German).

Hessen

On April 18, 2024, the B2G e-invoicing obligation took effect in the state of Hessen. Initially, public contracting authorities in Hessen would only receive e-invoices via e-mail to [email protected]. Now, as an alternative, e-invoices can also be uploaded to the state's portal.

The portal's main advantage is that it allows for submitting e-invoices with larger attachments, up to 100 MB, compared to the 22 MB limit for e-mail submissions. Currently, it is not possible to submit e-invoices via Peppol.

More details are available here (in German).

On March 18, 2025, the Ministry of Finance published a special regulation for small businesses (Sonderregelung für Kleinunternehmer), implementing EU Directive 2020/285. As of January 1, 2025, both the German VAT Act (Umsatzsteuergesetz) and the Annual Tax Act 2024 (Jahressteuergesetz 2024) have been updated.

Small businesses in Germany can claim tax exemption domestically for sales generated in other EU countries. However, if domestic small companies wish to claim tax exemption in other Member States, they must participate in the special reporting procedure (under Section 19a of the UStG), managed by the Federal Central Tax Office (BZSt).

Entrepreneurs established in other EU countries can also claim tax exemption under Section 19 of the VAT Act for services provided in Germany, provided they meet the requirements outlined in the VAT Act.

As previously reported, the eligibility threshold for being considered a VAT-exempt small business has increased to an annual turnover of no more than 25,000 EUR for the previous fiscal year and 100,000 EUR for the current fiscal year.

Current waivers will continue, allowing small business owners the option to waive their right to the exemption. Doing so enables them to participate in the VAT system like larger businesses.

On January 7, 2025, the state authorities of Bavaria announced adopting a single point of contact for invoice exchange, which aims to simplify invoicing, reduce throughput times, and speed up processing.

The chosen platform, OZG-RE, is currently used in other states such as Berlin, Brandenburg, Mecklenburg-West Pomerania, Saxony and Thuringia. OZG-RE has the following capabilities: web capture, upload, e-mail and sending via Peppol.

Although no exact date has been given, it is expected to happen in the first half of 2025.