Germany is planning a digital reporting system based on the e-invoice. Peppol, invoice service providers, and ERP integration are set to become key elements.
With the gradual introduction of mandatory e-invoicing, Germany is laying the foundation for the next step in digitalization: a transaction-based reporting system for VAT-relevant invoice data.
The Association for Electronic Invoicing (VeR) published a strategy paper in May 2026 describing how such a reporting system could be implemented efficiently. The central recommendation is: Tax data reporting should not become an additional, separate process, but should be directly integrated into the existing electronic invoice dispatch.
Since January 1, 2025, domestic companies have generally been required to be able to receive electronic invoices. The transitional arrangements for sending are being phased out gradually. From January 1, 2028, invoices in the domestic B2B sector must generally be issued as structured e-invoices, unless a statutory exception applies.
In parallel, the European ViDA initiative is introducing new digital reporting obligations for cross-border B2B transactions. The corresponding Digital Reporting Requirements are set to apply from July 1, 2030.
The planned German reporting system is intended to build on these developments. In the future, VAT-relevant data is to be extracted directly from the structured e-invoice and transmitted to the tax authorities as promptly as possible.
Important: The strategy paper describes a recommendation from the VeR. The final technical architecture and binding specifications of the German reporting system have not yet been fully determined.
Under the proposed model, sending an e-invoice triggers two interconnected data paths:
The complete electronic invoice is transmitted to the business partner or their invoice service provider.
The tax-relevant core data is extracted from the invoice and transmitted in parallel to the relevant tax authority department.
This should result in no additional manual work step for the company. The data is created once in the ERP or accounting system and then used for both invoice delivery and tax reporting.
The e-invoice remains the complete business document between supplier and customer. Only the legally defined reporting dataset is transmitted to the tax authorities.
The VeR recommends using the existing infrastructure instead of creating another isolated national portal. This includes in particular:
Peppol enables the secure and standardized exchange of electronic documents via certified Access Points. Senders and recipients can use different providers without having to set up a separate technical connection for each business partner.
For the future reporting system, an extended provider architecture is being discussed, in which the tax authorities are also integrated into the digital process alongside the sender, recipient, and their respective providers.
According to the strategy paper, invoice service providers are to assume a central role between companies, business partners, and tax authorities. Their possible tasks include:
Syntax, schema, mandatory fields, and compliance with EN 16931.
Conversion into the required invoice format as well as transformation of proprietary ERP data (IDoc, cXML).
Identification of the recipient and secure transmission of the e-invoice.
Extraction of the reportable core data and transmission to the tax authorities.
Status and error feedback as well as automatic retries in the event of temporary technical disruptions.
Traceable documentation of the entire processing chain.
Especially for small and medium-sized enterprises, a provider can significantly reduce technical and regulatory complexity. Companies do not have to implement different formats, transport routes, and reporting interfaces themselves.
Before the reporting system is introduced, various technical and organizational issues still need to be clarified.
Different profiles, extensions, and interpretations of individual mandatory fields can complicate automated processing. The VeR therefore recommends a binding minimum profile that must be supported by all systems involved.
Incorrect invoices or reports must be detected automatically. This requires uniform error codes, status messages, and rules for corrections. In addition to a complete rejection, acceptance with a note should also be possible, provided the error does not prevent further processing.
Many companies work with historically grown ERP, accounting, and document management systems. The reporting system should therefore be connectable via standardized APIs, interfaces, and connectors. The goal must not be the introduction of an additional portal with manual steps, but a fully integrated process.
Processing must remain guaranteed even during outages or maintenance. This requires, for example, queues, unique transaction numbers, automatic retries, and defined reporting deadlines.
A future reporting system requires clear role and permission concepts, tamper-proof logs, and a complete audit trail. Every processing step must be documented in a traceable manner.
Although the final specifications are still pending, companies can already prepare their systems and processes for the upcoming requirements:
Verify company, tax, and recipient identifiers for completeness and accuracy.
Ensure that e-invoices can be generated and received in accordance with EN 16931.
Check ERP, DMS, and accounting interfaces for their integration capabilities.
Gradually automate manual invoicing processes.
Establish processes for validation errors and status feedback.
Select providers with format conversion, Peppol connectivity, and integration options.
Generate invoice data in a structured format as early as possible in the process.
Those who view the e-invoice merely as a legally mandated output format are not utilizing a significant part of its potential. Structured invoice data forms the basis for automated verification, approval, posting, sending, receiving, and in the future, also for tax reporting.
Invoice-Portal already bundles essential components of end-to-end e-invoice processing:
This allows companies to gradually digitize their existing invoicing processes and create a technical foundation for future reporting obligations.
The planned reporting system is the logical next step in the evolution of mandatory e-invoicing. If implemented correctly, no additional reporting process will be created. Instead, invoice dispatch and tax reporting will be linked within a seamless digital workflow.
It will be crucial that Germany uses existing standards, providers, and networks, remains compatible across Europe, and gives companies enough time for testing and integration.
Companies should therefore not wait for the final specification, but should already review their data quality, interfaces, and e-invoicing processes today.
We will be happy to advise you on e-invoice formats, Peppol, conversion, and integration into your existing systems.
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