Questions about the German E-invoicing Mandate: Insights from Comarch and KPMG

Recently, we hosted a webinar entitled "E-invoicing in Germany: Achieve Legal, Technical, and Tax Compliance", featuring insights from e-invoicing experts Kamila Kania, Business Solution Manager at Comarch, and Christopher-Ulrich Böcker, Partner at KPMG Germany. This session focused on the upcoming changes in the German e-invoicing mandate, highlighting key deadlines and compliance requirements of which every business needs to be aware.

In this article, we address the questions raised by attendees during the webinar, providing clarity on how businesses can prepare for the transition.

If my supplier issues an e-invoice but I cannot receive it, does this affect my input tax deduction?

The supplier is responsible for issuing and transmitting the invoice correctly. As the buyer, you must receive and process it accurately to deduct input VAT. If technical or compatibility issues prevent you from receiving the e-invoice, this may affect your ability to claim input tax as you lack a legally valid document.

Starting January 2025, we cannot reject e-invoices in various syntaxes. What’s the best way to automate e-invoice receipt? Can we request vendors to use a single format?

Germany’s e-invoicing mandate supports multiple syntaxes (such as UN/CEFACT CII and UBL). While you can request a single format from suppliers, enforcing it may be impractical – it’s unlikely all of them would comply consistently.

A practical solution is implementing software, such as Comarch Email Converter, which automates validation and converts various formats into a standard format suitable for your ERP. This flexibility avoids disruption and ensures compliance.

Our solution supports all required syntaxes. For invoices that don’t meet format requirements, the tool can send automated error notifications to suppliers for correction.

Which other formats are compliant with EN16931, besides XRechnung and Edifact?

The European Standard on E-invoicing defines a set of technical and non-technical evaluation criteria to determine which syntax standards comply with the semantic model. The criteria and the evaluation of selected syntaxes are documented in CEN/TS 16931 Part 3-2, Section 5. As a result of this evaluation, two syntaxes are identified as compliant:

• UN/CEFACT CII (Cross-Industry Invoice) XML schema
• UBL (Universal Business Language) invoice and credit note messages, ISO/IEC 19845:2015

From a technical standpoint, several standards (using the syntaxes above) are compliant with EN 16931-1, provided that:

• They are issued, transmitted, and processed in a structured XML format that conforms to both the semantic data model of the standard and its specifications
• They are a valid instance of the XML schema definitions specified in EN 16931-2 (syntaxes mentioned above: UBL or CII)
• They comply with the business rules specified by the standard and their technical implementation

The following formats based on EN 16931-1 have been identified as commonly used in Germany and can be processed automatically by Comarch Email Converter:

Is the change more relevant to a company’s AP (invoice receiver) or AR (invoice issuer)?

The requirement primarily impacts accounts payable (AP), as AP departments need to receive, validate, and process e-invoices in compliant formats. With the Comarch Email Converter, AP departments can meet this obligation without requiring suppliers to use a specific format.

However, accounts receivable (AR) may also need to accommodate recipient format preferences, particularly if issuing invoices to German buyers.

Which format is most suitable for an EU-wide environment?

UBL is highly accepted across Europe and compatible with PEPPOL (Pan-European Public Procurement Online) standards. It’s user-friendly and widely supported by EU countries, making it suitable for cross-border invoicing.

What are the penalties if a supplier requests a PDF version instead of processing an e-invoice in a mandated format (e.g., XRechnung)?

While there are no direct penalties for requesting a PDF, delaying e-invoice processing may cause operational disruptions, delayed payments, and strained supplier relationships. While processing PDF invoices manually is possible, it may increase workload and decrease operational efficiency.

Implementing a solution such as Comarch E-invoicing mitigates risks by ensuring compatibility with multiple formats, enabling smooth and compliant processing.

Can accounts payable reject an already-paid invoice or identify duplicates sent in different formats?

There will be no requirement for the issuer to resubmit invoices previously sent in other formats and already paid. For duplicate invoices (e.g., one sent as a PDF and another as a CEN-compliant e-invoice), AP teams should validate that they are duplicates. With solutions such as Comarch E-invoicing, AP can mark the compliant e-invoice as a duplicate, ensuring no double payments.

What should I do if my suppliers are undecided about e-invoicing in Germany?

We recommend taking a proactive approach. Since some suppliers may transition to e-invoicing while others may not, it’s beneficial to implement a system that can handle both electronic (CEN-compliant) and traditional (PDF) invoices.

This flexibility ensures compliance with the new regulations, regardless of each supplier’s readiness. Additionally, consider reaching out to suppliers to encourage them to adopt a specified e-invoicing format.

My company uses MS365; can it be integrated with Comarch E-invoicing?

Yes, Comarch E-invoicing can be easily integrated with MS365, allowing seamless document management and streamlined workflows directly from your MS365 environment. For more details on the integration process, please contact our experts.

When are foreign companies supposed to start sending e-invoices to German entities?

Germany’s mandatory e-invoicing requirement, starting January 1, 2025, applies only to domestic B2B transactions. German companies must be ready to receive electronic invoices in a compliant format if suppliers choose to issue them this way. Currently, this mandate does not extend to cross-border transactions.

However, the European Commission’s ViDA initiative is exploring an EU-wide mandate, which could eventually require structured e-invoicing for intra-EU transactions to improve tax transparency and combat VAT fraud. Although no final decision has been made, future EU-wide regulations may introduce such requirements.

Are Austria, Switzerland, and Liechtenstein adopting Germany’s approach to e-invoicing?

Here’s how each country is currently managing e-invoicing:

• Austria mandates e-invoicing for federal government suppliers but keeps B2B e-invoicing voluntary
• Switzerland mandates e-invoicing for B2G and encourages hybrid formats (ZUGFeRD/Factur-X) for B2B, with no formal B2B mandate yet. Any format that complies with the Swiss Value Added Tax Act can be used
• Liechtenstein follows Swiss standards and promotes e-invoicing, especially for public administration. E-invoices must be in XML compliant with EN 16931 or PDF format

In the future, Austria will likely follow EU-wide mandates for B2B e-invoicing (such as ViDA). Switzerland may adopt standards that simplify trade within the EU, particularly Peppol-based standards, and Liechtenstein will likely continue to align its e-invoicing policies with Switzerland.

Will some suppliers exclusively use X-Rechnung (XML) format?

While X-Rechnung is common, suppliers may choose formats based on client needs. Solutions like Comarch E-Invoicing are invaluable as they support both X-Rechnung and multiple formats, ensuring seamless integration with suppliers’ preferences.

If a customer requests e-invoicing from January 2025, must businesses comply or can they continue with PDF?

Invoice issuers may still send PDFs and other non-EN-16931-compliant formats until 2027, but only with the recipient’s consent. Germany’s 2025 mandate requires AP departments to receive compliant e-invoices if suppliers choose to issue them electronically.

Comarch: Enhancing Compliance and Efficiency in E-Invoicing

With the upcoming e-invoicing mandate in Germany, it’s crucial for businesses to have a flexible system that can accommodate both electronic and traditional invoice formats. By adopting Comarch's EDI and e-invoicing solutions, companies can efficiently manage incoming invoices, ensuring compliance and minimizing operational disruptions.

If you have any questions about the e-invoicing regulatory changes in Germany or other countries, don’t hesitate to schedule a call with our experts.