Electronic invoicing is becoming increasingly important in Germany. While the federal government has mandated business-to-government (B2G) e-invoicing for its suppliers since November 2020, in compliance with EU Directive 2014/55/EU, the landscape of e-invoicing in Germany involves varying state-level requirements, specific formats, and upcoming business-to-business (B2B) obligations.
This article was last updated on 26 May 2025 to reflect the upcoming consolidation of the ZRE and OZG-RE invoice submission platforms.
While the federal mandate establishes a baseline for electronic invoicing (e-invoicing) in business-to-government (B2G) transactions, Germany’s federal states (“Bundesländer”) have their own e-invoicing regulations, leading to varying requirements for suppliers of state and local public administration bodies. Some states, such as Hamburg and Saarland, implemented e-invoicing obligations in 2022, while others have, to this date, still not yet mandated e-invoicing with all their suppliers.
Suppliers should be aware that specific e-invoicing requirements are determined by the laws of each individual state. Further information is provided here (in German only) by the Coordination Office for IT Standards (KoSIT). We recommend contacting the relevant state administration or your government customer directly to confirm specific regulations or other details, such as the buyer reference (the so-called “Leitweg-ID”).
Take a look at the nuances of Germany’s B2G e-invoicing mandates, the formats involved, and the country’s move towards business-to-business (B2B) regulations as well.
What constitutes an e-invoice in federal procurement?
According to Germany’s Ordinance on Electronic Invoicing in Federal Public Procurement (E-Rechnungsverordnung, or short, ERechV), invoices are considered electronic if they are issued, transmitted and received in a structured electronic format that enables the document to be processed automatically and electronically.
Generally, the XRechnung standard, Germany's local standard and an implementation of the European standard for electronic invoicing (EN 16931), in its most current version, must be used for B2G e-invoicing. However, another data exchange standard may be used if it also meets the requirements of EN 16931 (e.g. ZUGFeRD version 2.2.0 or later in the XRECHNUNG profile).
In addition to the specifications outlined in the European or XRechnung standards, Germany’s federal states may impose further requirements on local businesses. Alongside these specifications, businesses must also consider any additional requirements set out by the federal or state government.
Who has to send electronic invoices?
The E-Invoicing Ordinance (ERechV), adopted on 6 September 2017, mandates the use of electronic invoicing in federal public procurement and transposes EU Directive 2014/55/EU into German federal law.
Here's a timeline of key implementation dates:
- 27 November 2018: Supreme federal authorities and federal constitutional bodies were required to accept and process e-invoices in the XRechnung format.
- 27 November 2019: All other federal administrative authorities were required to accept and process e-invoices.
- 27 November 2020: All suppliers to federal contracting authorities became obligated to transmit e-invoices. However, direct orders with a net value of up to €1,000 are exempt (see Section 3, Subsection 3 of the ERechV for all exceptions).
In essence, the ERechV requires the federal administration to receive electronic invoices and the suppliers and service providers of the federal government to send electronic invoices for public contracts.
What format is required?
For B2G e-invoicing in Germany, the primary accepted format is XRechnung. This is a local German implementation of the European standard for electronic invoicing. XRechnung, which supports both CII (Cross-Industry Invoice) and UBL (Universal Business Language) as XML-based syntax, is designed to ensure machine-readability and seamless integration into processing systems.
While XRechnung is the primary standard, ZUGFeRD (Central User Guide of the Forum for Electronic Invoices in Germany) is also accepted under certain conditions. Introduced in 2013, ZUGFeRD provides a hybrid format using both a PDF/A-3 file (human-readable) and an embedded XML file (machine-readable) using the CII syntax, and is particularly widely used in B2B contexts. Specifically, ZUGFeRD version 2.2.0 or later in the XRECHNUNG profile is an acceptable B2G alternative to XRechnung as it meets the EN 16931 requirements.
Additionally, Peppol BIS Billing 3.0 is accepted for invoices from abroad to German public authorities.
German Federal E-Invoicing Platforms: ZRE and OZG-RE
The German federal administration currently uses two main platforms to receive electronic invoices: the Zentrale Rechnungseingangsplattform des Bundes (Central Invoice Submission Platform, short ZRE) and the Onlinezugangsgesetz-konforme Rechnungseingangsplattform (Onlinezugangsgesetz-konforme Rechnungseingangsplattform or Online Access Act-compliant Invoice Submission, short OZG-RE). The ZRE is used by organisations within the direct federal administration, while the OZG-RE is used by organisations within the indirect federal administration and cooperating federal states.
However, it is important to note that these platforms are in the process of being consolidated in 2025. The Federal Ministry of the Interior and Homeland Security (BMI) and the Federal Ministry of Finance (BMF) have decided to merge the ZRE into the OZG-RE. By the end of Q4 2025, the OZG-RE will be the sole federal platform for submitting e-invoices. This consolidation will create a unified access point for submitting invoices to the entire federal administration, thereby simplifying the process for suppliers.
Suppliers will be notified by their respective federal authorities of the specific transition date and provided with the necessary information. Registration on the OZG-RE is already possible. Once the transition is complete, the ZRE will no longer be available.
An overview (in German only) of which authorities are still linked to the ZRE and which are already linked to the OZG-RE can be found here.
Data retention and compliance with Germany’s GoBD
Beyond the formatting and transmission of e-invoices, businesses must adhere to the German “Principles for properly maintaining, keeping and safeguarding books, records and documents in electronic form as well as for data access” (Grundsätze zur ordnungsmäßigen Führung und Aufbewahrung von Büchern, Aufzeichnungen und Unterlagen in elektronischer Form sowie zum Datenzugriff, or short, GoBD). These principles, in their regularly revised iterations, regulate the proper storage of electronic records, including e-invoices.
If requested by the tax authorities, data subject to recording and retention obligations, as well as the structural information necessary for the evaluation of the data, must be provided by the audited company in a machine-readable format. All information substantiating the invoice, including structural data, must be retained in its original format. For electronic invoices, this means that the original electronic format must be preserved.
The introduction of B2B e-invoicing
Germany has approved the Growth Opportunities Act (“Wachstumschancengesetz”), which includes the mandatory B2B e-invoicing regulation. This act was approved by the German Bundestag on 17 November 2023 and by the Bundesrat on 22 March 2024.
Here's a breakdown of the key implementation dates and requirements:
- From 1 January 2025: All businesses must be capable of receiving e-invoices in the EN 16931 standard. Buyer consent is not needed for sending e-invoices in this format.
- Until 31 December 2026: Paper invoices and non-EN 16931 compliant e-invoices are still allowed, but only with the recipient's consent.
- From 1 January 2027: Businesses with a previous year's (2026) turnover of EUR 800,000 or more must issue e-invoices in EN 16931 or other agreed electronic formats where VAT information can be accurately extracted. EDI remains permitted provided that the VAT information can be extracted in EN 16931. For businesses in scope at this time, paper invoices will no longer be compliant.
- From 1 January 2028: The obligation to issue e-invoices is extended to all businesses. EDI remains permitted under the aforementioned conditions.
E-invoices must be in a structured electronic format, such as XRechnung or ZUGFeRD. Formats like PDFs or text emails will not be considered compliant.
For the latest updates and further details, take a look at Germany’s e-invoicing regulations.
Ensuring your compliance with Unifiedpost Group
Working with Banqup's e-invoicing solution provides your business with reassurance and peace of mind. Our solution is already tax and e-invoicing compliant in over 60 countries around the globe. We track daily regulation changes and adapt our solutions accordingly, so that your business remains compliant, without needing the expertise of e-invoicing experts.
To start your journey and easy transition to Unifiedpost Group’s solutions, contact a member of our local German team, who will listen to your e-invoicing and compliance needs.
Raoul, our Country Manager for Germany, has been with us since 2015. With over a decade of experience in business development and digital innovation, he specialises in advising B2B clients, especially in e-invoicing and digital collaboration. He's led the charge in transitioning global corporations from paper-based processes to digital solutions.
