e-invoicing in Germany
Germany, like many European countries, is on its way to implementing electronic invoicing requirements for domestic taxpayers of all shapes and sizes. However, e-invoicing is yet to be fully implemented and mandated in the country.
E-invoicing in Germany is currently divided by transaction type. There are national and federal requirements for B2G transactions, but the time hasn’t come for B2B transactions to utilise e-invoices yet. This will begin to change in 2025, and by 2028, all German businesses will be mandated to send and receive invoices electronically.
With Germany’s e-invoicing rollout fragmented and intensive to follow, use this page as your go-to overview to ensure you meet your obligations. Bookmark this page and revisit it whenever you need a reminder of the current requirements.
Table of contents
Germany B2B e-invoicing
CTC Type
- Post Audit
Network
- N/A
Format
- Compliant with EN 16931
eSignature Requirement
- Not mandatory, qualified e-signature can be used
Archiving Requirement
- 10 years
Germany B2G e-invoicing
CTC Type
- Decentralised/PEPPOL
Network
- Individual state platforms
Format
- Xrechnung & PEPPOL BIS
eSignature Requirement
- N/A
Archiving Requirement
- 10 years
E-invoicing regulations in Germany
Germany B2B e-invoicing
From January 2025, taxpayers must be able to receive electronic invoices. Sending and receiving e-invoices will become mandatory in Germany from 1 January 2027, applying to companies with an annual turnover exceeding EUR 800,000. From January 2028, it will apply to all companies.
This go-live date for German B2B e-invoicing was set in March 2024 when the Bundesrat passed the law known as ‘Wachstumschancengesetz’.
Germany B2G e-invoicing
E-invoicing is mandated when trading with public administrations, though it’s divided at a federal state level. There is a national mandate, but it runs alongside its 16 federal states – each of which has legislative freedom to develop its own e-invoicing platform.
The following German federal states have implemented e-invoicing for governmental transactions:
- Baden-Württemberg
- Bavaria
- Berlin
- Bremen
- Hamburg
- Hessen
- Lower Saxony
- Mecklenburg-Vorpommern
- North Rhine-Westphalia
- Rhineland-Palatinate
- Saarland
- Saxony
- Saxony-Anhalt
- Schleswig-Holstein
- Thuringia
The aforementioned European Directive (2014/55/EU) requires member-state government entities to be able to receive and handle electronic invoices according to the CEN standard, EN 16931.
Timeline: e-invoicing adoption in Germany
The implementation of e-invoicing in Germany can be hard to follow. Here are the main dates you need to know:
- April 2017: Germany publishes its e-Bill law
- 18 April 2020: Federal states implement mandatory e-invoicing in public procurement
- 27 November 2020: Public authorities must receive e-invoices from state authorities
- July 2023: Germany’s Federal Ministry of Finance presents draft legislation for mandatory e-invoicing
- 22 March 2024: Germany’s Federal Council approves a legislative package that includes the introduction of mandatory e-invoicing
- 1 January 2025: German taxpayers must be able to receive e-invoices from their suppliers (B2B)
- 1 January 2027: German taxpayers with an annual turnover of at least EUR 800,000 must issue e-invoices for B2B transactions
- 1 January 2028: Remaining German taxpayers must issue e-invoices for B2B transactions
Benefits of e-invoicing in Germany
Implementing electronic invoicing can benefit taxpayers by automating processes. Not only can this save time and headspace, it can also significantly reduce the risk of errors by removing the need for people to input and handle data manually.
Future of e-invoicing in Germany
While it’s now clear that there’s more to come on the e-invoicing front in Germany, there’s a larger initiative that could shift how the technology is implemented in the country – and across EU Member States at large.
VAT in the Digital Age is a proposal to digitize the European VAT system, implementing digital reporting and e-invoicing, among other new, innovative tax solutions.
It’s worth noting that while Germany is still working on implementing e-invoicing for all resident taxpayers, many countries are further along in their electronic invoicing journey. Global tax compliance can be tough, considering the nuances of each country’s tax digitization journey, but Sovos can help – wherever you do business.
Additional obligations for VAT compliance in Germany
While electronic invoicing is an important component of tax compliance in Germany, organisations have other obligations to stay on top of.
Staying updated with regulatory expectations becomes even more complicated when you consider the evolving nature of laws. Not only do you need to meet your current obligations, but you also need to stay on top of what’s to come – this is demanding in terms of both time and resources.
Non-compliance can be costly, but you don’t need to fall behind. Find out more about German VAT compliance with our dedicated overview.
FAQ
Is e-invoicing mandatory in Germany?
B2G e-invoicing is mandatory in Germany, and B2B e-invoicing is currently scheduled to come into effect from 1 January 2027 for companies with an annual turnover exceeding EUR 800,000.
Is e-archiving mandatory in Germany?
For B2G and B2B e-invoicing, German legislation requires the secure archival and access of electronic invoices for 10 years.
Will Germany make B2B electronic invoicing mandatory?
Germany has laid out plans to make B2B e-invoicing mandatory for resident taxpayers, following this timeline:
- 1 January 2025: Taxpayers must be able to receive e-invoices
- 1 January 2027: Taxpayers with an annual turnover exceeding EUR 800,000 must use e-invoices
- 1 January 2028: All taxpayers must use e-invoices.
What is the ZRE?
The ZRE stands for Zentrale Rechnungseingangsplattform des Bundes, which translates as Central Invoice Submission Portal. ZRE is a web portal that allows suppliers and service providers to send electronic invoices to federal entities.
What is the ZUGFeRD?
ZUGFeRD is a hybrid e-invoicing format that includes human-readable (PDF/A-3) and machine-interpretable invoice data. It’s based on XML, allowing invoices to be sent as attachments or embedded within an email.
ZUGFeRD meets the requirements of the European standard (EN 16931).
What is the XRechnung?
XRechnung is a standard for electronic invoicing that the German government accepted in late 2020. It was devised as a standard for converting invoice information into an XML data file, serving as an e-invoice.
XRechnung also meets the requirements of the European standard (EN 16931).
Who is required to use electronic invoicing?
B2G e-invoicing has been mandated at a national level since mid-2019, meaning that all Member State government agencies must be able to receive and manage electronic invoices.
Elsewhere, here’s the timeline for B2B e-invoicing in the country:
- From January 2025, all German taxpayers must be able to receive electronic invoices from their suppliers.
- From January 2027, all German taxpayers with an annual turnover of over EUR 800,000 must issue electronic invoices.
- From January 2028, all German taxpayers must issue and receive electronic invoices.
Which transmission methods can I use to send electronic invoices to federal contracting authorities?
When transacting with federal contracting authorities, you should send an electronic invoice through the relevant state’s individual transmission platform.
Setting up e-invoicing in Germany with Sovos
B2B e-invoicing has yet to be implemented in Germany, but it provides yet another obligation for organisations to meet once it is. Then, consider the other countries where you do business and the stages they may be at in their tax digitization journeys.
One solution is to pay attention to evolving mandates and regulations everywhere you operate. The more freeing solution is to appoint a single tax compliance partner, like Sovos, to do the busy work for you.
Trusted by the world’s best companies, including half the Fortune 500, Sovos’ solutions provide global compliance through local expertise.
