E-Invoicing in Germany
Updated: January 28th, 2021
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. However, electronic invoicing (e-invoicing) in Germany isn’t all that simple. Specific regulations vary across the country, so here’s everything you need to know, including important deadlines per 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.
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 upcoming 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-invoicing Law: Yes, see section 4a of the E-Government Act (EGovernment-Gesetz (EGovG)).
E-Invoicing Ordinance: Yes, see the E-Invoice Ordinance (E-Rechnungsverordnung (ERechV)).
Obligation to Accept E-Invoices: Yes, since November 27th, 2020 for all federal authorities.
E-Invoicing Obligation for Suppliers: Yes, since November 27th, 2020 to all federal authorities, with exceptions for individual orders of less than EUR 1000.
Methods of Invoice Receipt:
Leitweg-ID: The Leitweg ID is a mandatory part of the e-invoice. It is offered by the KK3 to the federal authorities, see: Die Letweg-ID eine Zusammenfassung (PDF). Suppliers receive the routing ID (Leitweg-ID) from the government authority to which they have to send the invoice.
Baden-Württemberg
E-Invoicing Law: Yes, see section 4a of Baden- Württemberg’s E-Government Act (E-Government-Gesetz Baden-Württemberg (EGovG BW)).
E-Invoicing Ordinance: Yes, see the state regulations of Baden-Württemberg.
Obligation to Accept E-Invoices: Since April 18th, 2020, public institutions in this state have been obliged to accept and process e-invoices with a contract value of EUR 1,000 or more. For municipalities and associations of municipalities, the obligation only applies to contract values above the thresholds.
E-Invoicing Obligation for Suppliers: From January 1st, 2022. Exceptions apply to individual orders with a value of less than EUR 1000 as well as to suppliers from countries outside the European Union.
Methods of Invoice Receipt:
Accepted Invoice Formats: XRechnung, or others in an EN-16931 format such as ZUGFeRD 2.0 (profile EN 16931).
Leitweg-ID: The routing ID (Leitweg-ID) is a mandatory part of the e-invoice. It is assigned by the country’s service portal and communicated to the biller by the customer.
Bavaria
E-Invoicing Law: Yes, see article 5 of the Bavarian E-Government Act (Bayerisches E-Government-Gesetz (BayEGovG)).
E-Invoicing Ordinance: Yes, see the Bavarian E-Government Ordinance ( Bayerische E-Government-Verordnung (BayEGovV)).
Obligation to Accept E-Invoices: Since April 18th, 2020 all public authorities in Bavaria are obliged to accept and process electronic invoices with a value of EUR 1,000 or more.
For municipalities, associations of municipalities, district offices, and other legal entities governed by public law under the control of Bavaria, these obligations apply in the first instance to contracts above the thresholds and from April 18th, 2022, as well as to contracts below the thresholds, starting at EUR 1,000.
For construction contracts with a value below the thresholds, the obligation is enforced beginning April 18th, 2023.
E-Invoicing Obligation for Suppliers: Currently the submission of electronic invoices in Bavaria is not mandatory.
Methods of Invoice Receipt: There is no central platform for receiving invoices in Bavaria, and electronic invoices are sent by email. In the future it is likely that this will occur via a web service through PEPPOL.
Accepted Invoice Formats: XRechnung, or others in an EN-16931 format such as ZUGFeRD 2.1 (profile EN 16931).
Leitweg-ID: The routing ID (Leitweg-ID) is not a mandatory part of the e-invoice.
Berlin
E-Invoicing Law: Yes, see the Berlin E-billing Act (Berliner E-Rechnungsgesetz (BERG)).
E-Invoicing Ordinance: Yes, see Berlin’s E-Invoicing ordinance (E-Rechnungsverordnung (ErechV)).
Obligation to Accept E-Invoices: Public authorities in Berlin have been obliged to accept and process e-invoices for contract values above the threshold values since April 18th, 2020. Starting December 31st, 2022, the obligation will apply to contract values starting at EUR 1,000.
E-Invoicing Obligation for Suppliers: No, there is currently no obligation for e-invoicing in Berlin. However, the use of electronic invoicing may be agreed upon between individual authorities and their suppliers.
Methods of Invoice Receipt:
Accepted Invoice Formats: XRechnung, or other in an EN-16931 format such as ZUGFeRD 2.1 (profile EN 16931).
Leitweg-ID: The routing ID (Leitweg-ID) is a mandatory part of the e-invoice. It is assigned for the State of Berlin by the Senate Department of Finance. Suppliers must receive the routing ID from the relevant government agency.
Brandenburg
E-Invoicing Law: Yes, see paragraph 5 of the Brandenburg E-Government Act (Brandenburgisches E-Government-Gesetz (BbgEGovG)).
E-Invoicing Ordinance: Yes, see the Brandenburg E-Invoice Ordinance (Brandenburgische E-Rechnungsverordnung (BbgERechV)).
Obligation to Accept E-Invoices: Yes, since April 18th, 2020, the acceptance of electronic invoices from the amount of EUR 1,000 via the administration portal has been mandatory for all authorities and institutions assigned to the Land of Brandenburg as a legal entity. There are exceptions in the area of contracts that require confidentiality, as well as in individual cases approved by the Ministry of Finance of the Land of Brandenburg.
Other authorities and institutions that are not assigned to the Land of Brandenburg as a legal entity may use the administrative portal or alternative procedures for receiving electronic invoices. Beginning on January 1st, 2025, the obligation to accept and process e-invoices will apply to public customers of the indirect state administration, municipalities in particular. This applies to both low- and high-threshold areas.
E-Invoicing Obligation for Suppliers: No.
Methods of Invoice Receipt:
Accepted Invoice Formats: XRechnung, or others in an EN-16931 format such as ZUGFeRD 2.1 (profile EN 16931).
Leitweg-ID: The routing ID (Leitweg-ID) is mandatory as part of the e-invoice. Suppliers must receive the routing ID from the relevant government agency. Further details can be found here.
Bremen
E-Invoicing Law: Yes, see paragraph 4 of the law to promote electronic administration in Bremen.
E-Invoicing Ordinance: Yes, see the regulation on electronic invoices in Bremen.
Obligation to Accept E-Invoices: Yes, it has been mandatory since November 27th, 2020, with exceptions for contract values below EUR 1,000 and for contracts that require confidentiality.
E-Invoicing Obligation for Suppliers: Yes, since November 27th, 2019 it is mandatory for order values from EUR 1,000 via the central invoice receipt platform, zERIKA.
Methods of Invoice Receipt:
Accepted Invoice Formats: XRechnung, or other in an EN-16931 format such as ZUGFeRD 2.1 (profile EN 16931).
Leitweg-ID: The routing ID (Leitweg-ID) is mandatory as part of the e-invoice. Suppliers must receive the routing ID from the responsible authority.
Hamburg
E-Invoicing Law: No, see publication.
E-Invoicing Ordinance: No, see pubilcation.
Obligation to Accept E-Invoices: Yes, since April 18th, 2020 according to the EU Directive for contracts above the thresholds.
E-Invoicing Obligation for Suppliers: No.
Methods of Invoice Receipt:
Accepted Invoice Formats: XRechnung, or others in an EN-16931 format such as ZUGFeRD 2.1, or in a PDF format.
Leitweg-ID: Suppliers must obtain the correct identification number from the relevant tax authority.
Hesse
E-Invoicing Law: Yes, see paragraph 5 of the Hessian E-Government Act (Hessisches E-Government-Gesetz (HEGovG)).
E-Invoicing Ordinance: Yes, see the E-Invoicing Ordinance (ERechnungsVerordnung (ERechV)) of the state of Hesse.
Obligation to Accept E-Invoices: Yes, since April 18th, 2020, for all authorities of the state of Hesse with an exception for individual orders under EUR 1000.
E-Invoicing Obligation for Suppliers: Yes, beginning April 18th, 2024, see publication. Exceptions apply when orders require confidentiality, for cash orders, and for existing contacts, for a maximum of 3 years.
Methods of Invoice Receipt: So far central submission is not possible. The invoice can be sent:
Accepted Invoice Formats: XRechnung, or others in an EN-16931 format such as ZUGFeRD 2.1 (profile EN 16931).
Leitweg-ID: The use of an identification number is required. This can be the format of the routing ID (Leitweg-ID). Suppliers must receive the identification number from the relevant government agency.
Mecklenburg-Western Pomerania
E-Invoicing Law: Yes, see the Mecklenburg-Western Pomerania E-Government Act (E-Government-Gesetz Mecklenburg-Vorpommern (EGovG M-V)).
E-Invoicing Ordinance: Not yet approved and/or published.
Obligation to Accept E-Invoices: Yes, since April 18th, 2020, for all authorities in the State of Mecklenburg-Western Pomerania. According to the current design, an electronic invoice is accepted regardless of the order value.
E-Invoicing Obligation for Suppliers: Not yet, this will begin on April 1st, 2023, with exceptions for cash and immediate payments. See available information.
Methods of Invoice Receipt:
Accepted Invoice Formats: XRechnung, or others in anEN-16931 format such as ZUGFeRD 2.1 (profile EN 16931).
Leitweg-ID: The routing ID (Leitweg-ID) is a mandatory part of the e-invoice. Suppliers must receive the routing ID from the relevant government agency.
Lower Saxony
E-Invoicing Law: Yes, see paragraph 6 of the Lower Saxony Law on Digital Administration and Information Security.
E-Invoicing Ordinance: Yes, see the Lower Saxony E-Invoice Ordinance (Niedersächsische E-Rechnungs-Verordnung (NERechVO)).
Obligation to Accept E-Invoices: Yes, since April 18tth, 2020.
E-Invoicing Obligation for Suppliers: No, so far there is no obligation. However, government institutions are encouraged to request e-invoicing when entering into a contract.
Methods of Invoice Receipt:
Accepted Invoice Formats: XRechnung, or others in an EN-16931 format such as ZUGFeRD 2.1 (profile EN 16931).
Leitweg-ID: The routing ID (Leitweg-ID) is a mandatory part of the e-invoice. Suppliers must receive the routing ID from the relevant government agency.
North Rhine-Westphalia
E-Invoicing Law: Yes, see paragraph 7a of the E-Government Law (E-Government Gesetz).
E-Invoicing Ordinance: Yes, see the E-Invoice Ordinance (E-Rechnungsverordnung (NRW)).
Obligation to Accept E-Invoices: Yes, since April 1st, 2020. There are no exceptions based on contract value; the obligation applies for values both above and below the thresholds. There are only exceptions for orders that require confidentiality.
E-Invoicing Obligation for Suppliers: No. The government may, however, request the supplier to send invoices electronically.
Methods of Invoice Receipt:
Accepted Invoice Formats: XRechnung, or others in an EN-16931 format such as ZUGFeRD 2.1 (profile EN 16931).
Leitweg-ID: The routing ID (Leitweg-ID) is not mandatory.
Rhineland-Palatinate
E-Invoicing Law: Yes, see the Rhineland-Palatinate E-Invoice Act (E-Rechnungs-Gesetz Rheinland-Pfalz (ERechGRP)).
E-Invoicing Ordinance: The corresponding ERechV RP has not yet been published.
Obligation to Accept E-Invoices: Yes, since April 18th, 2020, regardless of the contract or order value.
E-Invoicing Obligation for Suppliers: Not yet, this will begin on January 1st, 2024.
Methods of Invoice Receipt:
Accepted Invoice Formats: XRechnung, or others in an EN-16931 format such as ZUGFeRD 2.1 (profile EN 16931).
Leitweg-ID: The routing ID (Leitweg-ID) is a mandatory part of the e-invoice. Suppliers must receive the routing ID from the relevant government agency.
Saarland
E-Invoicing Law: Yes, see paragraph 10a of the Saarland E-Government Act (E-Government-Gesetz Saarland (E-GovG SL)).
E-Invoicing Ordinance: Yes, see the Ordinance on Electronic Invoicing in Public Procurement in Saarland.
Obligation to Accept E-Invoices: Yes, since April 18th, 2020, regardless of contract or order value.
E-Invoicing Obligation for Suppliers: Not yet, this will begin on January 1st, 2022 with exceptions for individual orders with a contract value of less than EUR 1,000, orders subject to confidentiality, and for suppliers from non-EU countries.
Methods of Invoice Receipt:
Accepted Invoice Formats: XRechnung, or others in an EN-16931 format such as ZUGFeRD 2.1 (profile EN 16931).
Leitweg-ID: The routing ID (Leitweg-ID) is a mandatory part of the e-invoice. Suppliers must receive the routing ID from the relevant government agency.
Saxony
E-Invoicing Law: Yes, see paragraph 3a of the Saxony E-Government Act (Sächsisches E-Government-Gesetz).
E-Invoicing Ordinance: Yes, see the Saxony E-Government Act Implementation Ordinance (Sächsische E-Government-Gesetz-Durchführungsverordnung).
Obligation to Accept E-Invoices: Yes, as of April 18th, 2020, the state is obliged to accept e-invoices both above and below the thresholds. Exceptions apply to confidential orders.
E-Invoicing Obligation for Suppliers: Yes, for the high-threshold area.
Methods of Invoice Receipt:
Accepted Invoice Formats: XRechnung, or others in an EN-16931 format such as ZUGFeRD 2.1 (profile EN 16931).
Leitweg-ID: The routing ID (Leitweg-ID) is a mandatory part of the e-invoice. Suppliers must receive the routing ID from the relevant government agency.
Saxony-Anhalt
E-Invoicing Law: Yes, see the Saxony-Anhalt E-Billing Law (E-Rechnungsgesetz Sachsen-Anhalt (ERG LSA)).
E-Invoicing Ordinance: Yes, see the E-Invoice Ordinance ( E-Rechnungsverordnung (ERechVO LSA)).
Obligation to Receive Invoices: Yes, since April 18th, 2020, regardless of the contract value, with exceptions for orders covered by the confidentiality obligation.
E-Invoicing Obligation for Suppliers: No.
Methods of Invoice Receipt:
Accepted Invoice Formats: XRechnung, or others in an EN-16931 format such as ZUGFeRD 2.1 (profile EN 16931).
Leitweg-ID: The routing ID (Leitweg-ID) is a mandatory part of the e-invoice. Suppliers must receive the routing ID from the relevant government agency.
Schleswig-Holstein
E-Invoicing Law: Yes, see paragraph 52g of the Act on the Modernization of Electronic Administration (Gesetz zur Modernisierung der elektronischen Verwaltung).
E-Invoicing Ordinance: Yes, see the E-Invoice Regulation (E-Rechnungsverordnung (ERechVO LSA)).
Obligation to Accept E-Invoices: Yes, since November 17th, 2019 for the state, and since April 18th, 2020 for municipalities. The obligation applies regardless of contract value for the state. For municipalities, however, the obligation only applies above the thresholds, with exceptions for orders covered by the confidentiality obligation.
E-Invoicing Obligation for Suppliers: No.
Methods of Invoice Receipt:
Accepted Invoice Formats: XRechnung, or others in an EN-16931 format such as ZUGFeRD 2.1 (profile EN 16931).
Leitweg-ID: The routing ID (Leitweg-ID) is a mandatory part of the e-invoice. Suppliers must receive the routing ID from the relevant government agency.
Thuringia
E-Invoicing Law: Yes, see paragraph 4a of the Thuringia E-Government Act (Thüringer E-Government-Gesetz (ThürEGovG)).
E-Invoicing Ordinance: Yes, see the Thuringia E-Invoicing Ordinance (Thüringer E-Rechnungs-Verordung (ThürERechVO)).
Obligation to Accept E-Invoices: Yes, since November 27th, 2019 regardless of contract value.
E-Invoicing Obligation for Suppliers: No. The government may, however, request the supplier to invoice electronically.
Methods of Invoice Receipt:
Accepted Invoice Formats: XRechnung, or others in an EN-16931 format such as ZUGFeRD 2.1 (profile EN 16931).
Leitweg-ID: The routing ID (Leitweg-ID) is a mandatory part of the e-invoice. Suppliers must receive the routing ID from the relevant government agency.
This blog was written by Julia Reijnen, Marketing Specialist based in Breukelen, the Netherlands and Christian Seidl, Managing Director of Sales and Marketing for the DACH region
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