Summary
- B2G mandate: No Business-to-Government (B2G) eInvoicing mandate exists, but since 1 November 2019, all public sector entities are required to receive and process structured eInvoices compliant with the European standard EN 16931[2], as mandated by the e-Bill law which transposes Directive 2014/55/EU. Businesses supplying goods or services to public authorities are encouraged to issue structured eInvoices compliant with the European standard EN 16931[3], because this guarantees that public authorities must accept these eInvoices.
- B2B and B2C mandates: There are no current business-to-business (B2B) or business-to-consumer (B2C) eInvoicing mandates. However B2B eInvoicing will become mandatory progressively from 2025. Under the Growth Opportunities Act, companies must be able to receive EN-compliant eInvoices as of 1 January 2025, while issuing becomes mandatory for large businesses from 2027 and for all businesses by 2028. B2C eInvoicing remains non-mandatory.
- eInvoicing standard: The European eInvoicing standard (EN 16931) has been adopted in Germany by public authorities. All public contracting authorities in Germany are required to accept and process electronic invoices that comply with the European Standard for eInvoicing for all public procurement contracts above EU Public Procurement thresholds [4]. Private suppliers are not legally required to issue eInvoices under EN 16931.
- Operating model for B2G eInvoicing: Germany operates a decentralised model for eInvoicing. Different authorities use different platforms (e.g., ZRE and OZG-RE), but a unified routing system using the “Leitweg ID” ensures interoperability. Authorities must offer Peppol as a transmission option if automated exchange is possible. Processing and acceptance vary by public entity and are often defined via bilateral agreements. Transmission channels include upload, web forms, email, De-Mail, and Peppol.
- Use of CIUS and Extensions: Germany has fully implemented the European eInvoicing standard under UBL 2.1 and UN/CEFACT CII syntaxes. XRechnung is the primary national CIUS and standard format. ZUGFeRD 2.1 is also accepted as a hybrid format (PDF + XML). Peppol BIS Billing 3.0 is additionally supported.
- VAT Real time reporting system: No real-time reporting system for eInvoicing is available.
- Monitoring mechanism: Germany has no mechanism to monitor eInvoicing developments.
Highlights
The Growth Opportunities Act sets a clear timeline for the transition to mandatory B2B eInvoicing in Germany, with businesses of varying sizes incorporated by 2028. Germany’s commitment to using specific formats like XRechnung and ZugFeRD ensures compliance with European standards, with future developments aimed at refining eInvoicing processes further.
B2G
Germany has a business-to-government (B2G) mandate.
No Business-to-Government (B2G) eInvoicing mandate exists, but since 2018, all public sector entities are required to receive and process structured eInvoices compliant with the European standard EN 16931[5], as mandated by the e-Bill law and eInvoicing Regulation, which transposes Directive 2014/55/EU. This rule applies when public authorities pay suppliers for goods or services provided through formal procurement contracts above the thresholds provided in the Public Procurement Directives[6]. Since 18 April 2020, authorities of the federated states are mandated to accept eInvoices.
B2B
As of March 23, 2024, the German Federal Ministry of Finance issued the Growth Opportunities Act, aimed at enhancing growth, investment, innovation, and simplifying taxes. Starting January 1, 2025, this Act mandates eInvoicing as the default method for issuing invoices in Germany's B2B sector, although it is not required for all businesses immediately. Companies need to be equipped to receive eInvoices in the EN 16931 format. Suppliers can still issue paper invoices and EDI invoices that do not comply with the EN standard, if they have the buyer's consent. This aligns with the European Value-added Tax in the Digital Age (ViDA) initiative, which supports the use of the EN 16931 European eInvoicing standard.
By January 1, 2027, businesses with a turnover exceeding EUR 800,000 will no longer be allowed to issue paper invoices or use unstructured electronic formats. By January 1, 2028, this requirement will extend to all businesses. On October 15, 2024, the German Federal Ministry of Finance published the final version of its eInvoicing guidelines, which largely retained the draft's content but included some clarifications and modifications. Importantly, the final version clarifies that simply providing an email address is sufficient to meet the eInvoice reception requirement starting January 1, 2025, and a dedicated electronic mailbox is not mandatory.
B2C
There is no business-to-consumer (B2C) mandate.
Status on the implementation of the European eInvoicing standard
The Coordination Office for IT Standards (KoSIT), located in Bremen, is tasked with maintaining the XRechnung standard and serves as the German Peppol Authority. This means KoSIT oversees the implementation and updates of these eInvoicing standards to ensure compliance and facilitate digital invoicing across Germany.
Germany supports the ZUGFeRD 2.1 format, which is a hybrid electronic invoice format that combines a PDF document with an embedded XML file. This format aligns with the European standard EN 16931 and allows for both human-readable and machine-processable invoicing, making it versatile for various business needs.
Operating model for eInvoicing
In Germany, eInvoicing for business-to-government (B2G) transactions varies by public authority, but the Leitweg ID system ensures efficient transmission to contracting authorities. The Federal Central Invoice Receiving Platform (ZRE) requires eInvoices in the XRechnung format for federal administrations, while the OZG-RE platform is an alternative, though not all states use it. Federal and national authorities must support Peppol transmission for automated data exchange, and businesses should use providers accredited by the German Peppol Authority.
Use of Core Invoicing Usage Specifications (CIUS) at national level
XRechnung and ZugFeRD 2.0/2.1 represent the national CIUS. EN. XRechnung is purely a digital data file, while ZUGFeRD 2.0 includes both a digital data file and a PDF that people can read. Besides XRechnung, national authorities in Germany can accept other eInvoice formats. Germany also has the option to use Peppol BIS Billing 3.0 for electronic invoicing.
VAT Real-Time reporting system
Currently, there is no real-time reporting system in Germany.
Next steps
Currently, there is no monitoring mechanism for eInvoicing in Germany.
NO VERIFICATION
[1] The European Standard on EU law sets minimum harmonised rules for tenders whose monetary value exceeds a certain amount and which are presumed to be of cross-border interest. More information can be found via: https://single-market-economy.ec.europa.eu/single-market/public-procurement/legal-rules-and-implementation/thresholds_en [2] The European Standard on eInvoicing (EN 16931) defines a common format and data model for electronic invoices, ensuring they are structured, machine-readable, and compatible across EU systems. [3] Ibid.2 [4] Ibid.1 [5] The European Standard on eInvoicing (EN 16931) defines a common format and data model for electronic invoices, ensuring they are structured, machine-readable, and compatible across EU systems. [6] Ibid 1.