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Compliance and Regulations

Electronic invoicing obligations for German businesses to public administration

September 1, 2023

Since the 27th of November 2020, suppliers of German Federal government institutions, have been obligated to send business-to-government (B2G) electronic invoices, aligning with European Directive 2014/55/EU.

The obligation for public body suppliers to send electronic invoices to remaining public administration bodies varies across Germany’s states. Certain states such as Hamburg and Saarland have required their suppliers to send electronic invoices since 2022, whereas some states are only demanding electronic invoices this year. This is because, as of April 2024 the obligation to send electronic invoices to all public administration bodies, will be mandatory in all states.

Take a look at the nuances of Germany’s B2G electronic invoicing (e-invoicing) mandates, the formats involved and the country’s decision to start moving towards business-to-businesses regulations as well.

What is an electronic invoice within the meaning of the German E-Invoice Ordinance?

According to the Federal E-Invoice Ordinance (ERechV), invoices are considered electronic if they are issued, transmitted and received in a structured electronic format. The format must enable the invoice to be processed automatically and electronically.

The requirements are described in the European standard EN-16931 or the XRechnung standard (Germany’s local standard) in the most current version.

Germany’s Federal States can also have further requirements for their local businesses. In addition to the specifications determined in the European or XRechnung standard, businesses must also take into account any further specifications required by the federal or state government.

Who has to send electronic invoices?

The E-Invoicing Ordinance of September 6, 2017 obliges the public administration to receive electronic invoices, and the suppliers and service providers of the federal government to send electronic invoices in the context of public contracts.

The acceptance and processing of e-invoices has been mandatory for the supreme federal authorities and federal constitutional bodies since the 27th of November 2018 and for all other federal administration authorities since the 27th of November 2019.

In addition, since the 27th of November 2020, all invoice issuers have also been obliged to transmit electronic invoices to federal contracting authorities. Direct orders with a net order value of up to €1,000 are exempt from this obligation (all exceptions: Section 3 (3) E-RechV).

What format is required?

The accepted format at a B2G level is XRechnung, a local German variation based on the European standard EN-16931.

In some cases ZUGFeRD is also accepted. In 2013, a uniform data format was published under the name ZUGFeRD (Central User Guide of the Forum for Electronic Invoices in Germany) so that invoices can be exchanged electronically between companies and companies and public administrations quickly, conveniently and easily.

What information is within the scope of the GoBD?

All information that is required to substantiate the contents of the invoice (including structural information) is relevant. The “outgoing invoice” must be kept in the format in which it was created (if electronic, then also in the original format). The BMF letter dated the 14th of November 2014 provides detailed information

The introduction of B2B e-invoicing

The "Bundesrat," which represents the federal states of Germany, has given its approval to a proposed law encompassing business-to-business (B2B) electronic invoicing.

The obligatory invoice issuance start date has been postponed from January 2026 to January 2027. Like many B2B mandates, the regulations will roll-out in stages depending on a business’ turnover.

If the current law passes, every German business would be obliged to have the infrastructure in place to receive XRechnung invoices from January 2025.

To view the latest law updates and business scope requirements, take a look at Germany’s e-invoicing regulations.

Ensuring your compliance with Unifiedpost Group

Working with Unifiedpost Group’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.

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