Updated - January 5th, 2024

Overview

As with other countries in the European Union (EU), the EU e-invoicing Directive 2014/55/EU made it clear that Germany had to make business-to-government (B2G) e-invoicing mandatory from April 18th, 2020. In this blog you will read everything you need to know about e-invoicing in Germany, including important deadlines by state.

German E-Invoicing Standards: XRechnung vs. ZUGFeRD

As of April 18th, 2020, all government agencies in Germany have to be able to receive and process e-invoices according to a standard in line with EU requirements. The e-invoicing regulations of the German federal government stipulated that XRechnung is the preferred standard for B2G e-invoices. This standard was developed by the German Coordination Office for IT Standards (KoSIT) and is an invoice format based on XML. The current XRechnung standard allows two XML formats for electronic invoicing: UBL or UN/CEFACT Cross Industry Invoice (CII).

Although XRechnung is preferred by the Federal Government, ZUGFeRD can also be used, as ZUGFeRD also complies with the European Standard. It consists of two components: a PDF file and an embedded XML file. ZUGFeRD is based on the UN/CEFACT CII standard and the ISO standard PDF/A3.

The German Peppol Authority: KoSIT

KoSIT became the German Peppol authority in June 2018, with the responsibility of maintaining XRechnung. KoSIT is part of the E-Government department within the core administration of the Free Hanseatic City of Bremen and is a permanent organization of the National IT Planning Council.

KoSIT's main tasks are to assist the IT Planning Council in adopting IT interoperability and IT security standards, as well as to manage joint federal and state e-government projects.

Deadline Compliance

You might assume that all government agencies in Germany have been able to receive e-invoices since April 18th, 2020. In reality, there are still public authorities—especially in the municipal sector—that cannot yet receive and process electronic invoices. This has to do with the federal structure, as all 16 federal states have their own constitutions, parliaments, and governments. In other words, it is usually the responsibility of each individual federal state to apply European requirements.

The structure, scope, and timing of electronic invoicing implementation is defined by the E-invoicing Act (E-Rechnungsgesetz) along with the associated ordinances of the respective state authorities in the individual federal states.

At state level, however, 16 separate laws and ordinances had to be drafted, optimized, and implemented on the basis of the EU Directive and the European Standard. To date, there are still federal states that have yet to issue regulations, and the ordinances that have already been issued may vary.

B2B E-Invoicing Obligation in Germany

From 2025, B2B companies in Germany will be obliged to issue e-invoices. The reason for this is the amendments to Section 14 UStG, in which a mandatory electronic invoice is also to be introduced in the B2B sector. On August 31, 2023, the Federal Cabinet approved this draft of the Ministry of Finance for the Growth Opportunities Act. On November 17, 2023, the Bundestag also passed the Growth Opportunities Act.

On February 23, the Bundestag approved the compromise on the Growth Opportunities Act. After intensive political disputes between the federal and state governments, the Bundestag passed the Growth Opportunities Act without the climate protection investment premium on Friday, February 23, 2024. 

On March 22, 2024, the Bundesrat approved the Growth Opportunities Act. According to the current draft of the Growth Opportunities Act, all domestic companies must be able to receive and archive electronic invoices from January 1, 2025. The e-invoice articles therefore remain unchanged.

For B2B (business-to-business) transactions, the requirements currently in the legislative process mean the end of paper invoices and unstructured PDFs. There is probably not much time left for implementation:

  • The obligation to receive will begin as early as 2025, the obligation to send two years later;
  • By 2028 at the latest, even small companies will only be allowed to send electronic invoices to their business partners;
  • All companies must be able to read and understand XML invoices.

How Can You Send E-Invoices in Germany?

As mentioned above, because of the varying regulations in Germany, there are many different specifications, threshold conditions, and technical approaches from state to state. It is important for B2G suppliers to know an consider these conditions.

For your convenience, here’s a list of recent deadlines for all of Germany:

January 1st, 2022: E-invoicing obligation for suppliers in Baden-Württemberg.

January 1st, 2022: E-invoicing obligation for suppliers in Saarland.

April 18th, 2022: Obligation to accept e-invoices below the thresholds and from EUR 1000 for municipalities, associations of municipalities, district offices and other legal entities under public law in Bavaria.

December 31st, 2022: Obligation to accept e-invoices at contract values from EUR 1000 and for the sub-threshold area in Berlin.

April 1st, 2023: E-invoicing obligation for suppliers in Mecklenburg-Vorpommern.

April 18th, 2023: Obligation to accept e-invoices for construction contracts below the thresholds in Bavaria.

January 1st 2024: E-invoicing obligation for suppliers in Rhineland-Palatinate.

April 18th,2024: E-invoicing obligation for suppliers in Hesse.

January 1st, 2025:Obligation to accept e-invoices for public customers of the indirect state administration, especially municipalities, in the Land of Brandenburg. This applies to both low- and high-threshold areas.

Below you can find the most important information at both federal and state level.

 

Federal Level

E-invoice law: Yes, see § 4a of the EGovG.

E-invoice regulation: Yes, see E-Rechnungsverordnung (ERechV).

Obligation to accept e-invoices: Yes, as of November 27, 2020 for all federal governments.

E-invoice obligation for suppliers: Yes, as of November 27, 2020 for all federal governments. With exceptions for individual orders of less than €1,000.

Options for receiving invoices:

The Leitweg ID: The Leitweg ID is a mandatory part of the e-invoice. It is offered by the KK3 to federal governments, see: The Leitweg ID a summary (PDF). Suppliers receive the Leitweg ID from the government agency to which they have to invoice.

Baden-Württemberg

E-invoice law: Yes, see § 4a of the E-Government Act of Baden-Württemberg (EGovG BW).

E-invoice regulation: Yes, see the regulations of the state of Baden-Württemberg.

Obligation to accept e-invoices: As of April 18, 2020, public institutions in this state will be required to accept and process e-invoices with a contract value of €1,000 or more. For municipalities or associations of municipalities, the obligation only applies to contract values above the threshold.

E-invoicing obligation for suppliers: From January 1, 2022. There are exceptions for individual contracts with a value of less than €1,000 and for suppliers from countries outside the European Union.

Options for receiving invoices:

  • Via the Federal Government's Central Invoice Receipt Platform (ZRE);
  • Manual entry via a web browser in the ZRE portal;
  • By e-mail;
  • By de-mail;
  • Via a web service through PEPPOL (planned).
  • Accepted invoice formats: XRechnung or in an EN-16931 format such as ZUGFeRD 2.0 (profile EN 16931).

Leitweg-ID: The Leitweg-ID is a mandatory part of the e-invoice. Suppliers receive the Leitweg-ID from the authority they have to invoice.

Bavaria

E-invoicing law: Yes, see Article 5 of the Bavarian E-Government Act (BayEGovG).

E-invoice regulation: Yes, see the Bavarian E-Government Ordinance (BayEGovV).

Obligation to accept e-invoices: As of April 18, 2020, all Bavarian public authorities will be required to accept and process electronic invoices with a value of €1,000 or more.

For municipalities, associations of municipalities, district offices and other legal entities under public law in Bavaria, these obligations initially apply to contracts above the threshold values and, as of April 18, 2022, also to contracts below the threshold values starting at 1,000 euros.

For construction contracts below the thresholds, the obligation will apply from April 18, 2023.

E-invoicing obligation for suppliers: To date, the submission of electronic invoices is not mandatory in Bavaria.

Options for receiving invoices: There is no central platform for receiving invoices in Bavaria. Electronic invoices are sent by e-mail. In the future, the possibility of sending e-invoices with a web service via PEPPOL will probably be added.

Accepted invoice formats: XRechnung or in an EN 16931 format such as ZUGFeRD 2.0 (profile EN 16931).

The Leitweg ID: The Leitweg ID is not a mandatory part of the e-invoice.

Berlin

E-invoicing law: Yes, see the Berlin E-Invoicing Law (BERG).

E-Invoice regulation: Yes, see Berlin E-Invoice Regulation (ErechV).

Obligation to accept e-invoices: As of April 18, 2020, public authorities in the state of Berlin will be required to accept and process e-invoices for contract values above the thresholds. As of December 31, 2022, the obligation will apply to contract values above €1,000.

E-invoicing requirement for suppliers: No, there is no general e-invoicing obligation yet. As an alternative to this rule, the use of electronic invoicing can be agreed between public authorities and suppliers.

Ways of receiving invoices:

The Leitweg ID: The Leitweg ID is a mandatory part of the e-invoice. It is assigned by the Senate Department of Finance for the State of Berlin. Suppliers must obtain the Leitweg-ID from the relevant state authority.

Brandenburg

E-invoice law: Yes, see paragraph 5 of the Brandenburg E-Government Act (BbgEGovG).

E-invoice regulation: Yes, see Brandenburg E-Billing Regulation (BbgERechV).

Obligation to accept e-invoices: Yes, as of April 18, 2020, the acceptance of e-invoices over €1,000 via the administration portal is mandatory for all authorities/institutions that are assigned to the state of Brandenburg as legal entities. There are exceptions in the area of contracts requiring confidentiality or in individual cases if approved by the Ministry of Finance of the State of Brandenburg.

Other authorities/institutions that are not assigned as legal entities to the State of Brandenburg may use the Administration Portal or alternative procedures to receive e-invoices. As of January 1, 2025, the obligation to accept and process e-invoices will apply to public clients of the indirect state administration, in particular municipalities. This applies to both low and high thresholds.

E-invoicing obligation for suppliers: None.

Ways of receiving invoices:

The Leitweg ID: The Leitweg ID is a mandatory part of the e-invoice. Suppliers must obtain the Routing ID from the relevant government agency. For more details, see the information on the Leitweg-ID of the State of Brandenburg.

Bremen

E-invoice law: Yes, see § 4 of the law for the Promotion of electronic administration in Bremen.

E-invoice regulation: Yes, see Bremen Electronic Invoice Ordinance.

Obligation to accept e-invoices: Yes, as of November 27, 2020. Exceptions apply to contract values below €1,000 and contracts requiring confidentiality.

E-invoicing obligation for suppliers: Yes, as of November 27, 2020, mandatory for order values above 1,000 euros via the central invoice receipt platform zERIKA.

Ways of receiving invoices:

  • Preferred web service via the invoice receipt platform (zERIKA);
  • Manual entry via the zERIKA portal;
  • Via web upload;
  • By e-mail;
  • Via De-Mail;
  • Via web service through PEPPOL.
  • Accepted invoice formats: XRechnung or in an EN-16931 format such as ZUGFeRD 2.1 (Profile EN 16931).

The Leitweg ID: The Leitweg ID is mandatory as part of the e-invoice. Suppliers must obtain the route ID from the relevant authority.

Hamburg

E-invoice law: Yes, see the Hamburg Law on Electronic Invoicing For Public Contracts.

E-invoice regulation: Yes, see Hamburg E-Invoicing Ordinance (HmbERechVO).

Obligation to accept e-invoices: Yes, as per EU Directive for contracts above thresholds, as of April 18, 2020.

E-invoicing obligation for suppliers: Yes, from a net amount of 1,000 euros for deliveries and services, 3,000 euros for construction services.

Ways to receive invoices:

  • Through the Central Invoice Receipt;
  • By e-mail, see registration page;
  • Using the e-invoicing portal 
  • Accepted invoice formats: XRechnung or in an EN 16931 format such as ZUGFeRD 2.1 (profile EN 16931).

The Leitweg ID: You can find a list of Hamburg Leitweg ID here. Suppliers must have the correct identification number from the relevant tax authority.

Hesse

E-invoice law: Yes, see paragraph 5 of the Hessian E-Government Act (HEGovG).

E-invoice regulation: Yes, see ERechnungsVerordnung (ERechV) of the State of Hesse.

Obligation to accept e-invoices: Yes, as of April 18, 2020, for all public authorities in the state of Hesse. There is an exception for individual orders under 1,000 euros.

E-invoicing requirement for suppliers: Yes, as of April 18, 2024, see publication. Exceptions apply for orders requiring confidentiality, for cash and existing contacts, for a maximum of 3 years.

Ways of receiving invoices: Currently no centralized submission. Invoice can be sent:

  • By e-mail;
  • Using a web service via PEPPOL (in consultation with the relevant government agency).
  • Accepted invoice formats: XRechnung or an EN 16931 format such as ZUGFeRD 2.1 (profile EN 16931).

The Leitweg ID: The use of an identification number is required. This can have the format of the Leitweg ID. Suppliers must obtain the identification number from the appropriate government agency.

Mecklenburg-Western Pomerania

E-invoice law: Yes, see the E-Government Act of Mecklenburg-Western Pomerania (EGovG M-V).

E-invoice regulation: Yes, see Mecklenburg-Western Pomerania E-Invoicing Ordinance - ERechVO M-V.

Obligation to accept e-invoices: Yes, as of April 18, 2020, for all public authorities in the state of Mecklenburg-Vorpommern. According to the current draft, an electronic invoice will be accepted regardless of the value of the order.

E-invoicing requirement for suppliers: Yes, as of April 1, 2023.

Invoice receipt options:

  • Manual entry via Bundesdruckerei's central invoice receipt platform (OZG-RE);
  • Via web upload;
  • By e-mail;
  • Via De-Mail;
  • Via web service via PEPPOL.
  • Accepted invoice formats: XRechnung or in an EN 16931 format such as ZUGFeRD 2.1 (Profile EN 16931).

The Leitweg ID: The Leitweg ID is a mandatory part of the e-invoice. Suppliers must obtain the Leitweg ID from the relevant government agency.

Lower Saxony

E-invoice law: Yes, see Paragraph 6 of the Lower Saxony Law on Digital Administration and Information Security.

E-invoice regulation: Yes, see Lower Saxony E-Invoicing Ordinance (NERechVO).

Obligation to accept e-invoices: Yes, as of April 18, 2020.

E-invoicing obligation for suppliers: No, there is no obligation yet. However, public entities are encouraged to request e-invoicing when concluding a contract.

Ways to receive invoices:

  • Via the central invoice receipt platform (E-Poststelle NATO);
  • Via web upload;
  • By e-mail;
  • In the near future, via De-Mail;
  • As of April 18, 2022, via a web service through PEPPOL.
  • Accepted invoice formats: XRechnung or in an EN 16931 format such as ZUGFeRD 2.1 (profile EN 16931).

The Leitweg ID: The Leitweg ID is a mandatory part of the e-invoice. Suppliers must obtain the Leitweg ID from the relevant government agency.

North Rhine-Westphalia

E-invoicing law: Yes, see Section 7a of the E-Government Act.

E-invoice regulation: Yes, see E-Invoice Regulation (NRW).

Obligation to accept e-invoices: Yes, as of April 1, 2020. There are no exceptions based on contract value. The obligation applies both above and below the thresholds. There are exceptions for contracts requiring confidentiality.

E-invoicing requirement for suppliers: No. However, the government agency may require the supplier to invoice electronically.

Options for receiving invoices:

  • Manual entry via the NRW portal;
  • Via web upload;
  • By e-mail;
  • By De-Mail;
  • Via web service through PEPPOL.
  • Accepted invoice formats: XRechnung or in an EN-16931 format such as ZUGFeRD 2.1 (Profile EN 16931).

The Leitweg-ID: The Leitweg-ID is not a mandatory part of the e-invoice.

Rhineland-Palatinate

E-invoicing law: Yes, see E-Rechnungs-Gesetz Rheinland-Pfalz (ERechGRP).

E-invoice regulation: Yes, see the E-Invoicing Ordinance Rhineland-Palatinate - ERechVORP.

Obligation to accept e-invoices: Yes, as of April 18, 2020, regardless of order or contract value.

E-invoicing obligation for suppliers: Not yet, as of January 1, 2024.

Ways to receive invoices:

The Leitweg ID: The Leitweg ID is a mandatory part of the e-invoice. Suppliers must obtain the Leitweg ID from the relevant government agency.

Sarland

E-invoice law: Yes, see § 10a of the E-Government Law Saarland (E-GovG SL).

E-invoice regulation: Yes, see Ordinance on Electronic Invoicing in Public Procurement in the Saarland.

Obligation to accept e-invoices: Yes, as of April 18, 2020, regardless of order or contract value.

E-invoicing obligation for suppliers: As of January 1, 2022. Exceptions apply to individual orders with a contract value of less than €1,000, orders subject to confidentiality obligations and suppliers from non-EU countries.

Methods of receiving invoices:

The Leitweg ID: The Leitweg ID is a mandatory part of the e-invoice. Suppliers must obtain the Leitweg ID from the relevant government agency.

Saxony

E-invoice law: Yes, see Section 3a of the Saxon E-Government Act.

E-invoice regulation: Yes, see Saxon E-Government Act Implementation Ordinance.

Obligation to accept e-invoices: Yes, as of April 18, 2020, the state is obliged to accept e-invoices both above and below the thresholds. Exceptions apply to contracts covered by the obligation of professional secrecy.

E-invoicing obligation for suppliers: Yes, above the thresholds.

Methods of receiving invoices:

The Leitweg ID: The Leitweg ID is a mandatory part of the e-invoice. Suppliers must obtain the Leitweg ID from the relevant government agency.

Saxony-Anhalt

E-Invoicing Law: Yes, see the E-Invoicing Law of Saxony-Anhalt (ERG LSA).

E-invoice regulation: Yes, see E-Invoicing Regulation (ERechVO LSA).

Obligation to accept e-invoices: Yes, as of April 18, 2020, regardless of contract value. Exceptions apply to contracts subject to confidentiality.

E-invoicing obligation for suppliers: No.

Ways to receive invoices:

  • Via the e-invoice portal of the state of Saxony-Anhalt;
  • Via web upload;
  • By e-mail;
  • Via De-Mail;
  • By using a web service via PEPPOL.
  • Accepted invoice formats: XRechnung or in an EN-16931 format such as ZUGFeRD 2.1 (Profile EN 16931).

The Leitweg ID: The Leitweg ID is a mandatory part of the e-invoice. Suppliers must obtain the Leitweg ID from the relevant government agency.

Schleswig-Holstein

E-invoicing law: Yes, see § 52g Law for Modernization of Electronic Administration.

E-invoice regulation: Yes, see E-Invoicing Regulation (ERechVO LSA).

Obligation to accept e-invoices: Yes, as of November 17, 2019 for the state and as of April 18, 2020 for municipalities. For the state, the obligation applies regardless of the contract value. For municipalities, the obligation applies only above the thresholds. Exceptions apply to contracts covered by the obligation of confidentiality.

E-invoicing obligation for suppliers: No.

Methods of receiving invoices:

The Leitweg ID: The Leitweg ID is a mandatory part of the e-invoice. Suppliers must obtain the Leitweg ID from the relevant government agency.

Thuringia

E-invoicing law: Yes, see Section 4a of the Thuringian E-Government Act (ThürEGovG).

E-invoice regulation: Yes, see Thuringian E-Invoice Regulation (ThürERechVO).

Obligation to accept e-invoices: Yes, as of November 27, 2019, regardless of order or contract value.

E-invoicing obligation for suppliers: No. However, the public authority can ask the supplier to send an electronic invoice.

Invoice receipt options:

The Leitweg ID: The Leitweg ID is a mandatory part of the e-invoice. Suppliers must obtain the Leitweg ID from the relevant government agency.

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