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

The Federal Cabinet passed the Growth Opportunities Act on 30 August 2023.

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


Nadia Schulte
+49 211 83 99 330

Want to know more?