E-Invoicing in Germany

Germany mandates e-invoicing for public sector procurement at the federal level through standardized formats and a unified portal, while regional implementation varies across federal states, each with its own rules, platforms, and timelines.

Country Situation

General Description

Germany is currently in the phased rollout of its mandatory B2B e-invoicing mandate, as established by the Growth Opportunities Act (Wachstumschancengesetz) and backed by EU authorization. The reform applies to domestic B2B transactions between businesses established in Germany and aims to harmonise invoicing practices through structured, machine-readable formats, fully aligned with the EN 16931 European standard.

A central national reporting platform is not currently in place, but the government has signaled future consideration of a portal for digital reporting or audit purposes. Additionally, there is no clearance or real-time reporting requirement yet, but Germany’s phased implementation allows flexibility to align with future ViDA digital reporting obligations.

FAQs

Is e-invoicing mandatory for all businesses in Germany?
Yes. As of 1 January 2025, receiving and processing electronic invoices conforming to the EN 16931 will become mandatory for domestic B2B transactions in Germany. This change was formalised through the publication of the Growth Opportunities Act, officially passed by the German Federal Council on 22 March 2024.
Who is the governing entity overseeing e-invoicing and digital reporting?
The German Federal Ministry of Finance (BMF) sets the regulations.
The Federal Central Tax Office (BZSt) oversees implementation.
For B2G transactions, each federal and state government agency manages compliance at its respective level.
Is there a phased implementation? What are the key deadlines for e-invoicing compliance in Germany?
1 January 2025: All businesses must be able to receive and process structured e-invoices

1 January 2027: Businesses with turnover over €800k must issue structured e-invoices

1 January 2028: All businesses must issue structured e-invoices

Is there a national e-invoicing platform in Germany?
No. There is no centralised platform for B2B e-invoicing. However, Germany's alignment with the EU’s VAT in the Digital Age (ViDA) suggests a centralized platform may be introduced in the future.
Do businesses need to register for e-invoicing compliance in Germany?
No. Registration is not required but businesses must ensure their e-invoicing solutions comply with German regulations.
How does e-invoicing work in Germany?
Businesses must issue and receive invoices in structured electronic formats, primarily through direct transmission or service providers.

E-invoicing in Germany follows these key steps:
- The supplier generates an invoice in an approved electronic format (e.g., UBL, CII, ZUGFeRD)
- The invoice is transmitted using a compliant method, such as Peppol or SMTP
- The recipient validates and processes the invoice
- The invoice is archived according to legal requirements
Is Peppol available, required, or recommended for e-invoicing in Germany?
Peppol is recommended but not mandatory.
What are the approved e-invoicing formats in Germany?
Germany supports e-invoices that comply with EN 16931, including:
- UBL 2.1
- CII (Cross Industry Invoice)
- ZUGFeRD (Hybrid PDF with embedded XML)
What is the process for foreign companies issuing e-invoices in Germany?
Foreign companies must adhere to existing German VAT invoicing requirements. Clarifications for foreign entities under the future B2B mandate are anticipated with upcoming regulations.
Does Germany require real-time reporting of invoices?
No. Real-time reporting is not currently required. However, Germany is expected to introduce a centralised reporting system in the future to align with the EU VAT in the Digital Age (ViDA) initiative.
Do non-resident companies need to comply with e-invoicing in Germany?
No. The mandatory e-invoicing requirement from 1 January 2025 specifically applies to domestic B2B transactions between German-based entities. Non-resident companies are not currently mandated to comply but must continue to meet existing VAT invoicing obligations.
What are the e-invoicing requirements for cross-border transactions in Germany?
Cross-border transactions currently follow standard VAT invoicing rules. Future e-invoicing obligations for such transactions will be clarified in forthcoming legislation.
Is an electronic signature required for e-invoices in Germany?
Not mandatory, but electronic signatures are strongly recommended to ensure authenticity and integrity.
How should e-invoices be archived to comply with Germany’s regulations?
E-invoices must be digitally archived for at least 8 years in compliance with GoBD guidelines, ensuring data security and retrievability.
Can e-invoices be stored outside Germany?
Yes. E-invoices can be archived within the EU, provided German authorities have immediate access. Specific compliance conditions apply for archiving outside the EU.
Where can I find official e-invoicing guidelines for Germany?
How can ecosio help my business do e-invoicing in Germany?
ecosio provides automated, compliant e-invoicing solutions, seamless integrations, format conversions (XRechnung, ZUGFeRD), and secure, compliant archiving.

Country Specs

Mandate StatusMandatory, Staggered Rollout
Mandate ScopeB2B
Model TypeInteroperability / Post-Audit
Government EntityBundesministerium der Finanzen (BMF) (Federal Ministry of Finance)
FormatsUBL 2.1, CII (Cross Industry Invoice), ZUGFeRD (Hybrid PDF + XML)
Infrastructure / PlatformNone. Currently, businesses exchange invoices directly (Post-Audit model). Future CTC platform details are yet to be announced.
E-signature RequiredNo
Key DeadlinesJanuary 2025: Businesses must be able to receive e-invoices
 
January 2027: Businesses with turnover > €800k must issue e-invoices
 
January 2028: All businesses must issue e-invoices
AR MandatoryNo. It will be required starting January 2027.
AP MandatoryYes
Peppol AvailableYes
Domestic TransactionsYes
Cross-border TransactionsExports: Voluntary
Imports: Voluntary (Germany aligns with ViDA for future cross-border invoicing)
Archiving Period8 years
Archiving AbroadAllowed under certain conditions

Country Situation

General Description

Germany has fully implemented mandatory B2G e-invoicing in line with EU Directive 2014/55/EU, with further optimization efforts now underway. Since April 2019, all federal government entities have been required to accept structured electronic invoices. As of November 2020, suppliers are obliged to issue e-invoices for contracts with the federal administration.

To comply with the directive, Germany enacted the E-Rechnungs-Gesetz and the E-Rechnungsverordnung, mandating the use of EN16931 compliant formats, including XRechnung and ZUGFeRD.

Currently, Germany is consolidating its two federal-level B2G e-invoicing platforms: - ZRE (used by the direct federal administration) - OZG-RE (used by the indirect federal administration and seven federal states)

As part of this consolidation, ZRE will be decommissioned by Q4 2025, and all federal B2G invoices will be routed through the OZG-RE portal, simplifying processes and reducing administrative overhead. The migration began in May 2025, with entities like the Bundeswehr Procurement Office leading the rollout.

At the regional level, Germany’s 16 federal states (Länder) have autonomy to define their own B2G invoicing rules, platforms, and access points. However, all must remain Peppol-compatible to ensure interoperability across the national infrastructure.

FAQs

Is e-invoicing mandatory for all businesses in Germany?
Yes. E-invoicing has been mandatory for public sector transactions (B2G) since 27 November 2020 for federal-level government entities and from 27 November 2019 for sub-central public entities.
Who is the governing entity overseeing e-invoicing and digital reporting?
The German Federal Ministry of Finance (BMF) sets the regulations.
The Federal Central Tax Office (BZSt) oversees implementation.
For B2G transactions, each federal and state government agency manages compliance at its respective level.
Is there a phased implementation? What are the key deadlines for e-invoicing compliance in Germany?
27 November 2019: Sub-central public entities must accept structured e-invoices.

27 November 2020: All federal government entities must process structured e-invoices.
Is there a national e-invoicing platform in Germany?
No central platform, but e-invoices must be submitted via XRechnung-compatible portals operated by federal and state authorities.
Do businesses need to register for e-invoicing compliance in Germany?
Yes, registration is required for businesses submitting invoices to German public sector entities. Suppliers must register on federal and state-operated e-invoicing platforms, which include:
- ZRE (Zentrale Rechnungseingangsplattform des Bundes): The federal government's invoice submission portal, required for suppliers invoicing federal authorities.
- OZG-RE (Onlinezugangsgesetz-Rechnungseingangsplattform): The state-level e-invoicing portal, used by many regional and municipal public entities.

Some state governments operate their own e-invoicing portals, requiring separate registration based on the contracting authority.
How does e-invoicing work in Germany?
Supplier must issue invoices in XRechnung format (or another EN 16931-compliant standard).

Invoices must be submitted via official government portals i.e. ZRE (Zentrale Rechnungseingangsplattform des Bundes) for federal agencies. This can be achieved using Peppol, direct upload and email submission.

Government agencies validate, approve, and process payments.

Invoice is archived according to public sector retention laws.
Is Peppol available, required, or recommended for e-invoicing in Germany?
Peppol is strongly recommended in Germany.
What are the approved e-invoicing formats in Germany?
In Germany, the approved e-invoicing formats are:

XRechnung

- This is the official and mandatory format for B2G (Business-to-Government) e-invoicing in Germany

- It is a structured XML format based on the European EN 16931 standard

- XRechnung is required for all invoices sent to federal public authorities since 27 November 2020

- It includes clearly defined data fields and does not support PDF attachments or visual layout features

ZUGFeRD

- Stands for “Zentraler User Guide des Forums elektronische Rechnung Deutschland”

- It is a hybrid format, combining a human-readable PDF/A-3 with embedded XML data (also based on EN 16931)

- Versions 2.0 and above are compliant with EU e-invoicing norms, and accepted for B2B and some B2G use cases, depending on the authority

- ZUGFeRD 2.1.1’s XRechnung profile ensures full compatibility with XRechnung requirements
What is the process for foreign companies issuing e-invoices in Germany?
The “Act on the implementation of Directive 2014/55/EU on electronic invoicing in public procurement” applies to all suppliers, including foreign companies, provided they are fulfilling a public contract with a German federal or state authority.
Do non-resident companies need to comply with e-invoicing in Germany?
Yes. Foreign suppliers must issue XRechnung invoices when invoicing German public sector clients.
What are the e-invoicing requirements for cross-border transactions in Germany?
Foreign suppliers must use XRechnung for public sector invoices
Is an electronic signature required for e-invoices in Germany?
Not mandatory, but electronic signatures are strongly recommended to ensure authenticity and integrity.
How should e-invoices be archived to comply with Germany’s regulations?
E-invoices must be digitally archived for at least 8 years in compliance with GoBD guidelines, ensuring data security and retrievability.
Can e-invoices be stored outside Germany?
Yes. E-invoices can be archived within the EU, provided German authorities have immediate access. Specific compliance conditions apply for archiving outside the EU.
Where can I find official e-invoicing guidelines for Germany?
How can ecosio help my business do e-invoicing in Germany?
ecosio provides automated, compliant e-invoicing solutions, seamless integrations, format conversions (XRechnung, ZUGFeRD), and secure, compliant archiving.

Country Specs

Mandate StatusMandatory
Mandate ScopeB2G
Model TypeInteroperability / Post-Audit
Government EntityBundesministerium der Finanzen (BMF) (Federal Ministry of Finance)
FormatsUBL 2.1, CII (Cross Industry Invoice)
Infrastructure / PlatformOZG-RE,ZRE,State-Level Portals
E-signature RequiredNo
Key Deadlines27 Nov 2018: Federal authorities (Bund) must be able to receive electronic invoices.

27 Nov 2019: Suppliers to federal authorities may submit electronic invoices (optional).

27 Nov 2020: E-invoicing becomes mandatory for federal suppliers (with limited exceptions).
AR MandatoryYes. For most federal and some state suppliers.
AP MandatoryYes
Peppol AvailableYes
Domestic TransactionsYes
Cross-border TransactionsExports: Voluntary
**
Imports:** Voluntary
Archiving Period8 years
Archiving AbroadAllowed under certain conditions

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