Regulatory updates - Germany

Germany's Federal Ministry of Finance (BMF) and Federal Ministry of Justice (BMJV) jointly presented a 26-point action plan aimed at tackling tax and financial crime. The plan aims to strengthen cooperation between financial and investigative authorities, pool expertise across federal and state levels, and use data analysis to minimize tax and financial fraud.

VAT e-reporting

One of the most significant developments for businesses is the proposed VAT reporting system. Businesses would report transactions near real time rather than in periodic returns, so that VAT fraud becomes visible sooner and can be countered more effectively. No technical details, scope, or timeline have been confirmed, though the approach suggests Germany's B2B e-invoicing mandate could serve as its technical foundation.

Archiving and data storage changes

Extended retention: the retention period for accounting documents would increase to 15 years to better preserve evidence for fraud investigations.

In-country data storage: companies would need to store copies of tax relevant data on mirror servers located in Germany. Key details on the type of data subject to the requirement are yet to be defined.

Next steps

All proposals remain at the policy stage, with no draft legislation or timetable yet in place. Businesses should nonetheless begin reviewing their VAT compliance, archiving, and data-residency strategies.

On December 18, 2025, XStandards for Purchasing (XStandards Einkauf) announced the publication of documentation for the German Electronic Business Address (GEBA).  

This unique electronic addressing scheme enables economic entities in Germany to identify senders and receivers in electronic business data exchange, particularly within the Peppol network. GEBA facilitates the unambiguous discovery and routing of electronic documents, such as e-invoices. 

GEBA builds on the German Business Identification Number (Wirtschafts-Identifikationsnummer, W-IdNr) and accommodates complex internal company structures through its flexible addressing capabilities. 

The implementation of GEBA remains voluntary, allowing businesses to use it in conjunction with other addressing systems. 

GEBA serves a similar purpose to France's "FRCTC Electronic Address" identifier scheme, as both support unambiguous participant identification and routing of, for example, e-invoices. Having a standardized national identifier scheme may represent a step toward a potential 5-corner DCTCE model for Germany in the future, where tax authorities are added as a reporting/oversight "corner" to the traditional exchange flow. 

The current specification and additional information about GEBA are detailed on the XStandards Purchasing website. 

On November 5, 2025, the Federal Ministry of Finance (Bundesministerium der Finanzen, BMF) published an updated version of its FAQ on the introduction of mandatory e-invoicing from January 1, 2025. 

The "October 2025" version of the FAQ maintains general definitions, transmission channels, and timelines, while introducing some key updates:  

• Foreign businesses with German VAT registration but no fixed establishment can indicate this status on invoices to justify exemption from e-invoice issuance requirements. Recipients may rely on this indication when exercising ordinary commercial care. 
• A new section explains that the VAT Act (Umsatzsteuergesetz, UStG) and the Federal E-Invoicing Ordinance (E‑Rechnungsverordnung des Bundes, ERechV) operate without a hierarchical relationship and must be followed in parallel within their respective scopes.  

One example highlights the different thresholds for requiring an e-invoice: the VAT Act mandates e-invoices for transactions over 250 EUR, while ERechV applies to federal B2G invoices from 1,000 EUR. The two regimes also differ regarding transmission channel requirements, with various options available under the VAT Act for B2B e-invoicing compared to the mandatory use of OZG-RE for federal B2G transactions. 

• The ELSTER viewer now supports both XRechnung and ZUGFeRD formats. 

The document includes additional information links for e-invoicing resources and updates legal references, including both BMF letters on e-invoicing dated October 15, 2024, and October 15, 2025, as well as the July 14, 2025, GoBD amendments concerning retention requirements.