E-invoicing in Germany

Business-to-government (B2G) e-invoicing is mandatory in Germany for transactions with administrations at the federal (national) level.

Germany is a federal state that grants its 16 individual states a degree of independence in regulating B2G e-invoicing. B2G e-invoicing requirements may therefore vary from one state to another.

At the state level, B2G e-invoicing is mandatory in seven states: Bremen, Hamburg, Baden-Württemberg, Saarland, Rheinland-Pfalz, Mecklenburg-Vorpommern, and Hessen. B2G e-invoicing is optional in the remaining nine states.

Germany uses the Peppol network for B2G e-invoicing, which enables businesses to exchange e-invoices with certain public authorities.

Businesses can also use Germany’s central government portals: the Central Invoice Submission Portal (ZRE), and the OZG-compliant Invoice Submission Platform (OZG-RE).

B2G e-invoices sent to supreme federal authorities and central constitutional bodies must be submitted via the ZRE. B2G e-invoices for indirect federal authorities, such as Germany’s Employment Agency, must be submitted via OZG-RE.

The Leitweg-ID is part of B2G e-invoices in Germany, and is used to determine which portal should be used:

• IDs starting with 991 use ZRE

• IDs starting with 992 use OZG-RE

Germany took a phased approach to the rollout of mandatory business-to-business (B2B) e-invoicing to allow businesses to adjust during a transitional period.

Since January 1, 2025, all businesses in Germany must be able to receive e-invoices. Invoice recipients no longer have the option to refuse an e-invoice or request another format. However, it is still possible to issue ‘traditional’ billing formats such as paper invoices or standard PDF during the transition period if the sender wishes to.

From January 1, 2027, businesses with a turnover of €800,000 or more in 2026 must be ready to issue e-invoices for B2B transactions. Businesses with a turnover below this threshold can still issue paper and/or PDF invoices.

From January 1, 2028, all businesses must be ready to issue e-invoices.

The German e-invoicing mandate determines compliant e-invoices to be: invoices in structured formats that are issued, transmitted, and received electronically and can be automatically processed. The format must be compliant with the European norm EN 16931. Structured formats are machine-readable. Standard PDF invoices are not machine-readable and no longer considered to be e-invoices in Germany.

Creating a human-readable version is not mandated; however, businesses can provide one if they wish. This can be done by using the hybrid PDF/A-3 format or generating a separate PDF. In the event of a discrepancy between the content of the XML and PDF, German law states that the information in the XML file takes precedence.

Existing EDI connections between businesses can be used during the transition period. From January 1, 2028, EDI connections can only be used if they are compliant with EN 16931.

E-invoices must comply with German principles for proper accounting, or ‘Grundsätze zur ordnungsmäßigen Führung und Aufbewahrung von Büchern, Aufzeichnungen und Unterlagen in elektronischer Form sowie zum Datenzugriff’ (GoBD) and German VAT invoicing requirements. For amounts over €250, invoices must include:

• Full name and address of the supplier

• Full name and address of the recipient

• Supplier and buyer VAT number or tax number

• Date of delivery or performance

• Sequential invoice number

• Invoice issue date

• Description of the goods or services

• Net amount broken down by tax rates and exemptions

• VAT amount

• VAT rate charged

• Total amount charged

• Any pre-agreed reductions in the amount (such as discounts)

• If applicable, a note indicating the reverse charge (tax liability of the recipient)

All invoices in Germany, including e-invoices, must be archived for 10 years. E-invoices in Germany do not need to be digitally signed.

With e-invoicing mandates in place, real-time reporting requirements will follow. Germany is a member state of the European Union (EU) and is obligated to adopt Digital Reporting Requirements (DRR) that are part of the VAT in the Digital Age (ViDA) package of reforms. It’s expected that Germany will implement a centralised reporting system comparable to that implemented in Italy. Under this system, businesses are required to report B2B transactional data to tax authorities in real time.

There are a small number of exemptions from B2B e-invoicing mandates in Germany. These include transactions that are exempt from VAT, invoices for transactions with a total amount less than €250, selected types of services like passenger transport, and non-domestic transactions where at least one party is not a domestic (Germany-based) business.