tegwick
5a7e4ac2d4
RISK-REG-0001: eight-year voucher period (BEG IV) confirmed against secondary sources and §147 AO. RISK-POL-0009/0002: positions unchanged; new restore evidence noted as partial. RISK-POL-0012: receiving duty still unowned; issuing phase-in dates added, flagged for confirmation. RISK-POL-0011: stays dormant. Co-Authored-By: Claude Opus 5 <noreply@anthropic.com> Assistant: claude-code Assistant-Model: opus Assistant-Process: 6903@bnt-lap001 Assistant-Session: 8319e8a8-ffa6-4eb3-b8bf-b29945628f89
71 lines
3 KiB
Markdown
71 lines
3 KiB
Markdown
---
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id: RISK-POL-0012
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type: legal-policy
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title: "E-invoicing"
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regime: "UStG §14 (as amended by the Wachstumschancengesetz), EN 16931, ViDA"
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status: active
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activates_when: "the estate is a German business receiving B2B invoices — already true"
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owner: risk-nexus
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written: "2026-08-20"
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cadence: 1h
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clean_streak: 1
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last_checked: "2026-09-22T06:26:29Z"
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next_check: "2026-09-22T07:26:29Z"
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checked_by: "worsch"
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---
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# RISK-POL-0012 — e-invoicing
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**Active now, on the receiving side.** Since 1 January 2025 a German business
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must be **able to receive** a structured electronic invoice conforming to
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EN 16931 for domestic B2B transactions. That obligation had no transition
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period: the issuing obligations are phased, the receiving one was not.
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Issuing obligations phase in afterwards, with thresholds by turnover. The
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estate should assume it will be required to issue conformant invoices before it
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notices the deadline, because the receiving obligation arrived that way.
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## What it requires of systems
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- An inbox that accepts a structured invoice (XRechnung, or ZUGFeRD's hybrid
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PDF/A-3 carrying the XML) and does not treat it as an attachment to be
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eyeballed.
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- Storage of the **structured original**. A rendered PDF is not the invoice; a
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human-readable copy alongside it is not sufficient by itself.
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- Retention per `RISK-POL-0009` — eight years for the voucher, in the original
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format it was received in.
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## Where it bears on this estate
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`markitect` and `binect-js` handle document flows, and `rapp-qonto`/`fin-hub`
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touch payment and banking records. None of them is currently claimed to be the
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receiving point for statutory invoices, and **this policy does not assign that
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role** — naming the system that must satisfy this is the owning repo's
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decision, not the register's.
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What the register records is that the duty exists, is live, and currently has
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no named owner in the estate.
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## Evidence that would show this is met
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A demonstrated receipt and archival of an EN 16931 invoice, retained in its
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structured form, retrievable at eight years.
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Not established. If a supplier sends one tomorrow, nobody here can say what
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happens to it — which is a small, ordinary, entirely fixable gap, and exactly
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the kind that only becomes visible when it is written down.
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**2026-09-22 review.** The position is unchanged. The receiving duty is live
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and still has no named owner in the estate, five weeks after this record was
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written. The issuing dates under §27(38) UStG are:
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- **2027-01-01** for businesses with prior-year turnover above EUR 800,000;
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- **2028-01-01** for everyone else.
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A turnover below the threshold therefore leaves about fifteen months, not
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three. This is from general knowledge of the Wachstumschancengesetz and has
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not been re-read against the current text. Confirm it before planning to it.
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## Reviews
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- **2026-09-22** — clean check: Receiving duty live, still no named owner; issuing phase-in dates noted (2027/2028), to be confirmed. Cadence instant → 1h (1 clean in a row); next check 2026-09-22 07:26Z.
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