E-Invoicing in Germany
Update November 24th, 2023
The Federal Ministry of Finance, BMF, has proposed mandatory e-invoicing for B2B companies will be required from January 2026. However, businesses have the option to voluntarily implement e-invoicing from 2025.
Achieving Compliance in Germany: An overview with mySupply
Germany has been a latecomer to digitalization and currently has a highly fragmented and complex setup for the exchange of electronic business documents.
Since November 2020, it has been mandatory in Germany to settle deliveries and services to all public institutions through e-invoicing (§ 3 E-Invoicing Ordinance, E-RechV).
Institutions in the federal administration, for example, receive e-invoices on the central federal invoice receiving platform (ZRE).
Several institutions in the indirect federal administration receive e-invoices via the online invoice receiving platform (OZG-RE), which complies with the law on online invoice receipt.
At the state level, the situation is more varied, and each state has its own legislation on e-commerce that must be taken into account. Several states, for instance, use the central solution called XRechnung, which has been endorsed by the German IT Planning Council.
Legislation
Since April 18, 2019, central public institutions in Germany have been required to be capable of receiving electronic invoices.
There is currently no specific legislation in Germany regarding B2B e-invoicing. However, the German Federal Parliament has urged the adoption of mandatory B2B e-invoicing to help combat VAT fraud. This follows the successes in Italy, Hungary, and the plans for Poland and France. There is already a public platform that small and medium-sized German companies can use called the Zentrales Rechnungseingangsportal OZG-RE platform.
What Can Be Exchanged?
Electronic Invoices and Credit Notes: The XRechnung standard has been developed to align/comply with EU specifications. Technically, XRechnung is a Core Invoice Usage (CIUS) of EN 16931. This specification is now in effect for national, regional, and municipal authorities. Additionally, the ZUGFeRD standard can be used. This is a French/German standard used for a kind of hybrid invoicing where PDF documents contain electronic XML documents as attachments.
How Are Electronic Business Documents Exchanged?
SRE (Zentrale Rechnungseingangsplatform)
The national German platform for receiving B2G (Business-to-Government) invoices is the ZRE (Zentrale Rechnungseingangsplatform) and can be accessed via https://xrechnung.bund.de/. Although this platform is federal, not all federal states use it. Some have their own solutions/portals. All portals offer different options for sending invoices. This includes online solutions for organizations without EDI capabilities.
Peppol Network
We are seeing an increasing number of German public organizations, including those at both the federal and municipal levels, supporting Peppol and invoice receipt through Peppol. Specifically, the following federal states in Germany, with more than 5,000 municipalities, are connected to Peppol and can theoretically be reached via this network.
Federal states already connected to Peppol:
- Hamburg
- Schleswig-Holstein
- Mecklenburg-Vorpommern
- Bremen
- Brandenburg
- Berlin
- Saxony-Anhalt
- Thuringia
- Saxony
- North Rhine-Westphalia
- Baden-Württemberg
Federal states in the process of implementing Peppol or have not yet started implementation:
- Lower Saxony
- Hesse
- Bavaria
- Rhineland-Palatinate
- Saarland
Tax Reporting / Tax Clearance
Germany does not yet have specific legislation in this area, but it is closely examining the EU’s VIDA proposal. There has been strong interest in promoting B2B e-invoicing legislation, with the initial proposal set for 2025. However, it has already been assessed that this is too short a timeline for such a radical implementation. If VIDA is implemented by the EU, German companies will have to report VAT information in real-time in 2028.
CTC or Tax clearance is on the agenda in the EU and, therefore, in Germany. One of the major topics on the financial agenda in the EU is ViDA (VAT In The Digital Age). European legislation is being developed for the use of e-invoicing and mandatory VAT clearance with national tax authorities to combat VAT fraud. In the EU, there is a vision of a future where invoices are electronic, and VAT is reconciled in real-time. The model for this has not yet been determined.
Archiving Requirement
10 years of archiving for electronic invoices and credit notes.
