Aligning German VAT Rules to the European e-Invoicing Standard (EN 16931)

Germany has published a guide aligning its VAT Act (UStG) requirements with the European e-invoicing standard EN 16931, ensuring that all mandatory invoice details are mapped to structured fields like invoice date, number, and supplier data. This harmonization, developed jointly by KoSIT, FeRD, and AWV, provides a clear reference for issuers and software providers, reducing legal risks and enabling more consistent, automated B2B e-invoicing.

A new guide has been published to make B2B e-invoicing in Germany more consistent. It shows how the mandatory information required by the German VAT Act (UStG) can be matched to the European e-invoicing standard EN 16931-1.

The goal is to give invoice issuers, software providers, and service companies a clear reference so that e-invoices meet legal requirements while also following a common technical standard. This helps ensure legal compliance and smooth processing of electronic invoices.

The work is a joint effort between major e-invoicing groups in Germany:

• KoSIT / XStandards Einkauf (xeinkauf.de): responsible for the XRechnung standard,
• FeRD: maintaining the ZUGFeRD hybrid format,
• AWV (Arbeitsgemeinschaft für wirtschaftliche Verwaltung e.V.): supporting the project.

How does the mapping work?

 The core of the initiative is a table that links UStG requirements with EN 16931 fields.

Examples:

• Invoice date (§14 Abs. 4 Nr. 3 UStG) → “BT-2 Invoice issue date”
• Invoice number (§14 Abs. 4 Nr. 4 UStG) → “BT-1 Invoice number”
• Supplier’s name and address (§14 Abs. 4 Nr. 1 UStG) → “BG-4 SELLER” and “BG-5 SELLER POSTAL ADDRESS”

For special cases, the guide gives detailed instructions:

• Reverse charge: the phrase “Steuerschuldnerschaft des Leistungsempfängers” should be entered in “BT-120 VAT exemption reason text.”
• Cash-based accounting (§14 Abs. 4 Nr. 6a): use “BT-1 Invoice note” with the text “Versteuerung nach vereinnahmten Entgelten” and add “BT-7/BT-8 VAT point date.”

This ensures every legally required field has a standard place in the structured e-invoice.

Having one clear mapping prevents different interpretations and reduces legal risks. It also makes automation easier.

Future updates are planned. For example:

• Prepayment and final invoices currently need to be attached separately, but structured support is expected in future EN 16931 revisions,
• Additional requirements from Commercial Law (HGB) and payment details will also be added.

In short, this guide is a big step toward uniform and reliable e-invoicing in Germany, with more improvements coming.