Managing Electronic Documents in Germany
As a customer in Germany, you can exchange electronic documents through the Peppol eDelivery Network. Additionally, you can receive electronic documents directly into Continia Document Capture via email attachments.
On March 22, 2024, a new law was passed requiring B2B electronic invoicing using EN16931-compliant formats by January 2028.
Important
Germany's Bundesrat approved the Wachstumschancengesetz on March 22, 2024, mandating B2B electronic invoicing starting in January 2027 for companies with turnovers exceeding €800,000 and in January 2028 for those with turnovers below this threshold. However, all companies must be equipped to receive electronic invoices from January 2025 onwards.
Since November 27, 2020, all regional public contracting authorities in Germany (Länder) are required to use electronic invoicing. The transmission of electronic documents can be done by using the Peppol eDelivery network or by using portals such as ZER (Zentrale Rechnungseingangsporta), OZG-RE (Onlinezugangsgesetz-konforme Rechnungseingangsplattform), or any other local portals.
Note
EN16931 is a European standard that specifies a common semantic structure for electronic invoices to ensure consistent interpretation and processing across different systems. Electronic formats like XRechnung, Peppol BIS 3.0, and ZUGFeRD are compliant with this standard.
The table below outlines the current regulatory states and future outlooks for B2G, B2B, and B2C (business-to-consumer) sectors.
| Transaction Type | Current Regulatory State | Regulatory Outlook |
|---|---|---|
| B2G | Since April 2020, all federal and state contracting authorities have implemented a system for receiving and processing electronic invoices through central, regional, and local authorities. Supported by Document Capture. Supported by Document Output. | No changes are expected. |
| B2B | Electronic invoicing between B2B companies is possible through Peppol eDelivery. Supported by Document Capture. Supported by Document Output. | Starting from January 2025, businesses in Germany must be able to receive structured electronic invoices that are compliant with the EN16931 standard. The suppliers can still send invoices in non-compliant electronic formats, paper, or PDF. From January 2027 businesses with a turnover larger than €800,000 must, without the buyer’s consent, send electronic documents, even if the format is not EN16931 compliant. From January 2028 all businesses must send and receive electronic documents that are EN16931 compliant. |
| B2C | No legislation is in place. | No changes are expected. |
Regions and formats
It is important to note that in Germany, the implementation of structured electronic invoicing is mandated on a regional level. Compliance involves adhering to EN16931 standards, meeting portal-specific terms of use, and fulfilling requirements outlined in the federal E-Invoicing Ordinance (E-Rechnungsverordnung, E-RechV.)
What to know:
Portal requirements - there are different portals available for businesses, depending on the authority they are associated with:
- ZRE portal - the federal government, state, and district authorities require invoice submissions via the ZRE portal.
- OZG-RE portal - institutions that are associated with the federal government require invoice submissions via the OZG-RE portal.
- Regional platforms - despite centralized options such as ZRE and OZG-RE, German regions have the option to define their own localized platform for electronic invoicing. For example, the following regions are using other local invoicing portals: Baden-Württemberg, Bavaria, Bremen, Hamburg, Lower Saxony, North Rhine Westphalia, Saarland, Saxony-Anhalt, and Schleswig-Holstein.
XRechnung format - the XRechnung format is based on the EN16931 European electronic invoicing standard, and if registered to the OpenPeppol network, it can be sent to the intended receiver regardless of which government or localized platform they are attached to. The XRechnung format is generally accepted by all platforms.
Supplier obligations - as a supplier, you must be registered with the ZRE portal even though you send the documents via Peppol eDelivery.
On October 15, 2024, the German Federal Ministry of Finance (BMF) published the final version of its letter regarding e-invoicing, which retains many contents from the draft version but includes clarifications and adjustments. Notably, the draft version stated that a separate electronic mailbox is necessary to meet the requirement for receiving e-invoices from January 1, 2025, while the final version clarifies that this is not required, and providing an email address is sufficient. Furthermore, the Peppol BIS e-invoice format has now been included as an example of permissible European invoice formats, while the previously mentioned Italian format, FatturaPA, has been omitted.