Ministry of Finance ignores the reality of SMEs - DStV warns of collapse of proven invoicing processes due to overambitious e-invoice regulation.
One year after its initial publication, the Federal Ministry of Finance presents a modified e-invoicing rule catalog that reveals fundamental audit deficits. In its statement S 06/25, the German Tax Consultants' Association attacks the lack of implementation clarity and calls for concrete sanction limits for technical glitches.
Critical weakness: The tax authorities conceal their monitoring mechanisms and leave SMEs and their tax experts in a regulatory vacuum. This planning uncertainty poses a significant threat to proper compliance implementation. The DStV insists on leniency in the case of purely mechanical defects and demands application-oriented guidelines instead of theoretical constructs.
While financial politicians originally suggested continuity between paper and digital invoices, the current draft masks a fundamental transformation of the system. Construction industry invoices will be hit particularly hard: Modifications to services will in future force complete re-creations instead of established supplementary procedures. In addition, the BMF concept eliminates proven document references in favor of complete data integration in structured XML formats. This restructuring generates massive storage requirements and workflow disruptions. The Tax Consultants' Association brands this bureaucratization offensive as hostile to SMEs and propagates the retention of established procedures.
At least the BMF has corrected its originally restrictive small business doctrine: the approval requirement for sending e-invoices to commercial recipients no longer applies following DStV intervention. This liberalization confirms the association's lobbying work and demonstrates political influence in the case of excessive regulatory approaches.
Parallel infrastructure plans for 2030 sales data collection are already mobilizing resistance from the DStV. The association is fighting for an exclusive intermediary position between taxpayers and authorities and is blocking direct reporting system concepts. At the same time, the DStV is defending traditional pre-notification procedures against simplification efforts. Argument: Invoice data alone does not enable proper tax determination - a position that ensures the relevance of the profession but hinders progress in digitalization. The Tax Consultants Association positions itself as a quality guardian against technocratic automation and defends complex consulting structures in the SME segment. This fundamental opposition reflects the battle between digital transformation and traditional tax consultancy for market dominance in the German compliance sector.