Regulatory updates - Germany

The semantic data model now has more than 50 new business terms. Key changes include:

• BT-10 "Buyer reference" can be given more than once
• XML attachments are allowed in the core invoice
• The new BG-35 "Early payment discount" replaces the existing discount scheme
• The new BG-34 "Charges on behalf of a third Party" covers third-party claims
• More detailed delivery information can be included
• One invoice can reference multiple orders and deliveries

The full XRechnung 4.0 bundle is expected in spring 2027.

For more detailed information on the technical changes, please refer to the official release.

The federal cabinet has adopted a new draft law to modernize cash register systems and receipt practices across Germany. The initiative targets roughly 115,000 "open cash registers" still in use nationwide. These systems have minimal or handwritten sales records, making them vulnerable to manipulation and tax fraud.

Businesses with annual turnover exceeding EUR 100,000 will be required to replace open cash registers with electronic point-of-sale systems by 2028. Taxpayers with annual cash sales under EUR 12,000 are exempt. Additional exemptions may be added later by statutory order, potentially covering trust-based payment setups like self-harvest farm stands. Starting in 2028, businesses will also shift from paper receipts to digital receipts as the standard. This will limit fraud opportunities and improve detection of tax evasion.

This draft law is one piece of a larger action plan to combat tax and financial crime. The plan also includes ongoing efforts toward tax simplification, such as standardized and flat-rate taxation and streamlined tax return processes.

The timeline was announced by state secretary Michael Schrodi at an event organised by the German electronic invoice association (VeR). He confirmed that the legislative process will begin in 2027, followed by a voluntary pilot from early 2029. The reporting system is then targeted to go live and become mandatory from July 1, 2030.

While the key dates have now been set, technical details are still awaited. Businesses nonetheless should use this time to begin the preparation.

As a reminder, this reporting system builds on top of Germany's ongoing B2B e-invoicing mandate, which is being rolled out in stages. Since January 1, 2025, businesses have already been required to receive structured electronic invoices compliant with the EN 16931 standard. The obligation will soon extend to the issuing side:

• January 1, 2027: mandatory issuance for taxpayers with prior-year turnover above EUR 800,000
• January 1, 2028: mandatory issuance for all remaining taxpayers