Germany (2020 eInvoicing Country Sheet)

Legislation

The e-Bill law, published in April 2017, and the Regulation on eInvoicing from September 2017 mandate the receipt and processing of eInvoicing for all federal contracting authorities, regardless of the amount of the invoice[4]. The e-Bill law also provides for specific dates for the implementation of electronic invoicing: from 27.11.2018, the top federal state authorities must be able to receive and process electronic invoices and, from 27.11.2019, all subordinate institutions and sectorial contracting authorities on the federal level. There will be an obligation to accept eInvoices regardless of the value of the contract awarded.

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 supplementary legislation by the federal states (Länder).

On the federal states level (Länder) the Directive is largely transposed into supplementary legislation in the federal states (Länder). In the supplementary legislation by the federal state level (Länder) the specific dates for the implementation of electronic invoicing can be extended until at the latest April 2020.

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 eInvoicing platform depends on which public authority is to be addressed.

Some private companies offer eInvoicing Solutions, some of the solution providers can also be publicly-owned.

The formats in use will be for minimum XRechnung and all other standards compatible with the European Norm (EN) 16931.

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.

eInvoicing implementation in sub-central level contracting authorities 

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

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

Due to the federal structure in Germany, the federal government and the 16 federal 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 federal 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. The XRechnung is a Core Invoice User Specification (CIUS) of the European Norm (EN) 16931 on eInvoicing. 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 (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. The implementation is preceded by a period of evaluation. At the end of the evaluation period, it will be decided whether to make the use of PEPPOL mandatory.

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.

Monitoring eInvoicing implementation

Since the acceptance obligation begins in large parts on 18 April 2020, no statement can yet be made about the usage statistics.

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

XRechnung and ZugFeRD 2.0 are used as a Core Invoice User Specification (CIUS) and it follows the European Norm (EN) 16931 on eInvoicing. National authorities can accept other formats next to XRechnung. Germany may also make use of the PEPPOL CIUS.

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] Gesetz zur Umsetzung der Richtlinie 2014/55/EU über die elektronische Rechnungsstellung im öffentlichen Auftragswesen* Vom 4. April 2017

[2] ZUGFeRD stands as shorthand for "Central User Guide Forum electronic invoice Germany". The ZUGFeRD data format is based on the Cross Industry Invoice (CII) of UN/ CEFACT, ISO Standard 19005-3:2012 (PDF/A-3), as well as the Message User Guidelines (MUG) specified on a European level. 

[3] FeRD is the Forum for Electronic Invoicing in Germany

[4] 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.

VERIFIED BY EMSFEI MEMBER

Last updated:  Feb 03, 2021 15:39