On 5 November 2025 the German Ministry of Finance (MoF) published an update to the e-invoicing FAQs in their website.
These FAQs focus primarily on tax-related questions arising from Germany’s new mandatory e-invoicing regime, which came into effect in January 2025.
The key issues addressed in the FAQs are the following:
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Established entities in Germany: e-invoicing obligation applies to businesses established in Germany.
The updated FAQs clarify that non-established but VAT-registered entities may explicitly indicate their non-established status in the invoices they issue. This helps make clear that they fall outside the scope of the mandatory e-invoicing requirements.
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Transitional period: while all taxpayers must be able to receive structured electronic invoices from 1 January 2025, the requirement to issue (send) such invoices in B2B transactions will be introduced gradually.
The FAQs confirm that during the transitional period — which may extend until 2028 for some taxpayers — businesses may continue to issue paper invoices or non-compliant formats, depending on their size and readiness.
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Small Businesses Exemption: in line with the clarifications introduced in the latest BMF letter, the FAQs reaffirm that small businesses (Kleinunternehmer) are exempt from the obligation to issue e-invoices. However, these entities must still be able to receive e-invoices in the structured format defined by the new standard.
For future updates on Germany and similar developments in other countries, follow our Regulatory Analysis page.
