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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
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.
| Mandate Status | Mandatory, Staggered Rollout |
| Mandate Scope | B2B |
| Model Type | Interoperability / Post-Audit |
| Government Entity | Bundesministerium der Finanzen (BMF) (Federal Ministry of Finance) |
| Formats | UBL 2.1, CII (Cross Industry Invoice), ZUGFeRD (Hybrid PDF + XML) |
| Infrastructure / Platform | None. Currently, businesses exchange invoices directly (Post-Audit model). Future CTC platform details are yet to be announced. |
| E-signature Required | No |
| Key Deadlines | January 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 Mandatory | No. It will be required starting January 2027. |
| AP Mandatory | Yes |
| Peppol Available | Yes |
| Domestic Transactions | Yes |
| Cross-border Transactions | Exports: Voluntary Imports: Voluntary (Germany aligns with ViDA for future cross-border invoicing) |
| Archiving Period | 8 years |
| Archiving Abroad | Allowed under certain conditions |
Country Situation
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.
| Mandate Status | Mandatory |
| Mandate Scope | B2G |
| Model Type | Interoperability / Post-Audit |
| Government Entity | Bundesministerium der Finanzen (BMF) (Federal Ministry of Finance) |
| Formats | UBL 2.1, CII (Cross Industry Invoice) |
| Infrastructure / Platform | OZG-RE,ZRE,State-Level Portals |
| E-signature Required | No |
| Key Deadlines | 27 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 Mandatory | Yes. For most federal and some state suppliers. |
| AP Mandatory | Yes |
| Peppol Available | Yes |
| Domestic Transactions | Yes |
| Cross-border Transactions | Exports: Voluntary ** Imports:** Voluntary |
| Archiving Period | 8 years |
| Archiving Abroad | Allowed under certain conditions |
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