eInvoicing in Germany

Legislation

The e-Bill law, published in April 2017, and the Regulation on eInvoicing from September 2017 mandate the reception and processing of eInvoices for all federal contracting authorities, regardless of the amount of the invoice[1]. The e-Bill law also provides for specific dates for the implementation of eInvoicing: from 27 November 2018, the top federal state authorities must be able to receive and process eInvoices and, from 27 November 2019, all subordinate institutions and sectorial contracting authorities on the federal level. Since 27 November 2020, the issuing and processing of eInvoices to all Federal governments’ public contracting authorities is mandatory[2]^,[3]. It is mandated that eInvoices are issued, processed and accepted in XRechnung format to and by all central public authorities[4] as well as to and by all authorities of the state of Bremen.

The law applies exclusively to regulations for federal agencies (including sectorial contractors and licensors). The state or local authorities affected by the Directive 2014/55/EU require additional legislation by the federal states (Länder).

On the federal level (Länder), the Directive is fully transposed into supplementary legislation. Since 18 April 2020, authorities of the federated states are mandated to accept eInvoices[5].

eInvoicing platform and eInvoicing management solutions

There are different eInvoicing platforms mandated or recommended by the German government for B2G public procurement. The obligation to use a specific eInvoicing platform depends on which public authority is to be addressed. Despite the existence of multiple platforms, Germany has implemented a unified routing system. This routing ID (Leitweg ID) allows the invoicing platform to transmit eInvoices to public contracting authorities. The Leitweg ID is a mandatory element in the XRechnung schema, each ID is composed of a state code, fine addressing and check digit, while government, district and municipal codes remain voluntary.

The Federal Central Invoice Receiving Platform (ZRE) a central federal incoming invoice platform was developed to support federal administrations in receiving and accepting eInvoices. While the ZRE obliges all companies to submit eInvoices in the XRechnung standard, a second platform has been developed for suppliers (the online access law-compliant invoice receipt platform, OZG-RE). However, not all federal states use the OZG-RE as most of them have a portal at the federal level.[6]

The formats in use are XRechnung, to a lesser extent the hybrid ZuGFeRD 2.0[7] and all other standards compatible with the European Norm (EN) 16931. In addition, all authorities at federal and national level are mandated to always offer a Peppol transmission if an automated data exchange is provided for the delivery of eInvoices. The XRechnung format being specific to Germany, economic operators should select a provider that is accredited by the German Peppol Authority. This ensures that the service provider conducts Peppol transactions in Germany. German Peppol requirements available here.

Some private companies offer eInvoicing solutions, some of these service providers can also be publicly-owned.

The transmission channels differ according to the authority: upload, online form, e-Mail, De-Mail, web service (for minimum Peppol – the decision is taken by the National IT Planning Council).

Approach for receiving and processing eInvoices

Most eInvoicing operations are conducted following bilateral agreements between public entities and economic operators (or solutions providers acting on their behalf).

The approach for receiving and processing eInvoices submitted by economic operators is decentralised. Public entities receiving eInvoices decide whether to process eInvoices as structured data or according to a non-automated process. The Peppol network can be used with Peppol BIS 3 standards as well as XRechnung (cf explanations in section 2).[8]

Within the B2G context issuing of eInvoices is mandated for all suppliers to all federal and Bremen contracting authorities, while receiving is mandatory for all public contracting authorities (Federal central government authorities as well as federated state authorities). For B2B transactions, no explicit requirements exist for the issuing, while for receiving the buyer’s consent is required[9].

EInvoices do not need to be electronically signed and need to be archived for ten years, which, under conditions, is possible abroad[10].

eInvoicing implementation in sub-central level contracting authorities 

The implementation at the federal level differs depending on which public contractor is addressed. Therefore, it is necessary to contact the public contractor before invoicing. 

Each federated state may choose to implement the model determined by the Core Invoice User Specification (CIUS) or an own eInvoicing standard for the sending, receiving and processing of eInvoices to state authorities. Supplier to federal authorities must issue eInvoices in either Xrechnung format or another format that meets the European standard requirements from 27 November 2020[11].

Similarly, each state may choose whether the central government’s platform (Zentrales Rechnungseingangsportal OZG-RE) is used for processing the eInvoices or whether an own platform is used.

• Berlin, Brandenburg, Mecklenburg-Vorpommern, Saxony, and Thuringia are using the central government’s platform, while
• Baden-Württemberg, Bavaria, Bremen, Hamburg, Lower Saxony, North Rhine Westphalia, Saarland, Saxony-Anhalt, and Schleswig-Holstein are using other (local) invoicing portals[12].

More details on the eInvoicing solutions at state level authorities available

Status on the implementation of the European Standard on eInvoicing (EN)

Due to the federal structure in Germany, the federal government and the 16 states must each pass their eInvoicing laws to implement the Directive. On the federal level, the E-bill law is in place since 2017. On the state level, the different laws have been passed.

As part of the implementation of the Directive 2014/55/EU on electronic invoicing in public procurement in Germany, the National IT Planning Council has made two decisions:

• In June 2017, it was mandated for public authorities to receive and process XRechnung invoices. National authorities can accept other formats next to XRechnung.
• In April 2018, it was decided to establish a standard web service for public authorities to transport eInvoices (i.e. Peppol). The decision on timeline and conditions for using and joining the Peppol eDelivery Network for federal, regional and local authorities was made in October 2018 (with special consideration of the involvement of local authorities). National authorities can accept other ways of transport of eInvoices. 

As part of these decisions, the Coordination Office for IT Standards (KoSIT) was given the responsibility to maintain XRechnung and to become the German Peppol Authority. KoSIT is located within the eGovernment division of the core administration of the Free Hanseatic City of Bremen but is a permanent organisation of the National IT Planning Council.

Germany also offers the usage of ZUGFeRD 2.1 which is a hybrid eInvoice format. ZUGFeRD includes two elements: a PDF file and an embedded XML file. ZUGFeRD is based on the international UN/CEFACT standard Cross Industry Invoice (CII) and the ISO standard PDF/A-3. The latest version ZUGFeRD 2.1 complies with EU Directive 2014/55/EU and the German E-Invoice Regulation[13].

Monitoring eInvoicing implementation

In 2019 it was projected that about 32,000 million eInvoices are transacted every year in Germany[14]. A survey in December 2019 showed that approximately every third enterprise, employing more than 500 people, has already been using eInvoicing, while among smaller enterprises only every fifth did so[15].  As federated state authorities have been mandated to accept eInvoices in November 2020 only, more up-to-date statistics need to be awaited.

Use of Core Invoicing Usage Specifications (CIUS) at national level

XRechnung and ZugFeRD 2.0/2.1 represent the national CIUS for eInvoicing and are compliant with the EN.  XRechnung is a pure data record while an eInvoice in standard ZUGFeRD 2.0 is composed of a data record and a human-readable document in the form of a PDF. National authorities can accept other formats next to XRechnung. Germany may also make use of the Peppol BIS Billing 3.0.

Additional information

The German eInvoicing Forum (Forum elektronische Rechnung Deutschland – FeRD) is an important organisation in the German eInvoicing ecosystem. The FeRD was founded by the Working Group for Economic Management (Arbeitsgemeinschaft für Wirtschaftliche Verwaltung e.V. - AWV) in 2010. It aims to foster the use of eInvoicing in the public and private sectors. The FeRD is an industry-neutral forum, composed of members from ministries and other governmental bodies and important industry associations. FeRD is a voluntary organization based on contributions and resources from its members and experts.

[1] In this sense, the e-Bill law goes further than the Directive 2014/55/EU which makes eInvoicing compulsory for any amount above the determined threshold, [2] (§ 3 E-Rechnungsverordnung (ERechV), 2020), [3] (§ 11 E-Rechnungsverordnung (ERechV), 2020), [4] (Meininger, 2020), [5] (Update on E-invoicing in the German Federal States, 2021), [6] (Targa, Trent, 2020), [7] (Neitzel, 2020), [8] (Targa, Trent, 2020), [9] (Compliance updates Germany, 2021), [10] (Compliance updates Germany, 2021), [11] (Targa, Trent, 2020), [12] (Update on E-invoicing in the German Federal States, 2021), [13] (GERMANY AND E-INVOICING FOR B2G MANDATORY BY 27 NOVEMBER 2020, 2020), [14] (E-Invoicing in Germany: progress and current status, 2019), [15] (Zahorsky, 2020)

Last updated:  Jun 29, 2021 11:59