E-INVOICING IN GERMANY
Does your company operate in Germany? Ensure compliance with current and upcoming e-invoicing requirements.
Germany already requires electronic invoicing for deliveries to public institutions, and with a complex setup of federal platforms, state-level solutions, and multiple standards, it can be difficult for a Danish company to navigate. At the same time, mandatory B2B e-invoicing is on the horizon as part of the EU’s ViDA initiative by 2030.
With mySupply, you ensure compliance across German platforms and standards, whether it’s XRechnung, ZUGFeRD, or Peppol. We handle the technical integration so you can focus on your business.
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Achieving Compliance in Germany: An overview with mySupply
Germany has been a latecomer to digitalization and currently possesses a highly fragmented and complex setup for the exchange of electronic business documents. However, with the passing of the «Wachstumschancengesetz» (Growth Opportunities Act) in March 2024, development has accelerated.
As a German-registered company, you are subject to the new rules for B2B e-invoicing introduced back in 2025. With a VAX360 document platform, you ensure compliance with German legislation. All established e-invoice formats can be sent and received via VAX360 as standard. The VAX360 platform is connected to the Peppol network and other VANS networks, enabling the delivery and receipt of e-invoices to and from German companies. This includes the reception and processing of the ZUGFeRD hybrid PDF format.
VAX360 allows you to convert to and from your ERP formats (SAP, Oracle, Microsoft, etc.) to the mandatory German e-invoice formats.
Legislation
In 2024, the German Bundestag passed a new law (Wachstumschancengesetz) aimed at promoting economic growth, simplifying taxes and duties, and ensuring competitiveness among German companies. This legislative package introduced central regulations for the mandatory implementation of e-invoicing in Germany. The obligation to use e-invoices according to the new law applies exclusively to German B2B companies.
Germany already has an existing e-invoicing implementation for B2G (Business to Government). Since November 2020, it has been mandatory to settle deliveries and services to all public institutions via e-invoicing (cf. § 3 of the E-Invoice Ordinance, E-RechV). Furthermore, since April 18, 2019, it has been mandatory for central public institutions to be able to receive electronic invoices.
Timeline for the German B2B e-invoice law:
| Date | Legislation | Permitted invoice formats |
| January 1, 2025 | All German companies must be ready to receive e-invoices. Voluntary issuance of e-invoices by suppliers. | ZUGFeRD, XRechnung, Xinvoice (all EN16931 compliant). Paper and PDF. EDIFACT, X12 etc |
| January 1, 2027 | German companies with a turnover exceeding EUR 800,000 are required to send e-invoices in valid formats | ZUGFeRD, XRechnung, Xinvoice (EN16931 compliant). Paper and PDF (only with buyer permission). EDIFACT, X12 etc. (only with buyer permission). |
| January 1, 2028 | All German companies must issue B2B e-invoices. Paper and PDF via email will no longer be permitted. | ZUGFeRD, XRechnung, Xinvoice (EN16931 compliant). EDIFACT, X12 can be used if they are EN16931 compliant. |
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 hybrid invoicing, where PDF documents contain electronic XML documents as attachments.
How Are Electronic Business Documents Exchanged?
ZRE (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
In a B2G context, the Peppol network or specific portals are used. The national German platform for receiving B2G invoices is the ZRE (Zentrale Rechnungseingangsplatform). Although this platform is federal, not all federal states (Bundesländer) use it; some utilize their own solutions, such as OZG-RE.
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
For B2B, the exact channels to be used remain uncertain as Peppol is not explicitly mentioned in the new law. Distribution will likely be a mix of Peppol, email, AS2, sFTP, and other known exchange channels.
Tax Reporting / Tax Clearance
The choice of EN16931 as the underlying standard in Germany is closely linked to the upcoming European VAT directive, ViDA (VAT in the Digital Age). This requires companies to send real-time data to their local tax authorities.
By implementing the same invoice standard, Germany ensures a strong starting point for the ViDA directive, which is expected to take effect in 2030 (when German companies must report VAT information in real-time). Consequently, CTC (Continuous Transaction Controls) or Tax Clearance is high on the agenda to address and combat VAT fraud in the EU.
Archiving Requirement
There is a 10-year archiving obligation for electronic invoices and credit notes in Germany.
