Germany is moving toward a fully digital invoicing model, with obligations that will affect both business‑to‑business (B2B) transactions and those between businesses and the public administration (B2G). The e‑invoicing framework is overseen by the German Federal Ministry of Finance (BMF).
Business‑to‑consumer (B2C) transactions are not affected by this national mandate. In addition, cross‑border and intra‑EU operations are not yet included (without prejudice to the future requirements of ViDA).
E‑invoicing for the German public administration
In the public sector, Germany uses a centralized system in which all public administrations receive electronic invoices through standardized infrastructures.
The Bund (federal level) and many public entities receive e‑invoices through platforms such as ZRE/OZG‑RE and/or via Peppol, while in the Länder (federal states) there are specific portals or channels that may vary depending on the administration.
The accepted formats are XRechnung, Peppol BIS (via Peppol), and, in certain cases, ZUGFeRD.
E‑invoicing is mandatory for all B2G transactions.
German B2B model: how e‑invoicing works
The B2B obligation generally applies to transactions between “inländische” entrepreneurs, that is, companies with their registered office, address or establishment in Germany. There are some exceptions, such as certain types of tickets considered invoices, low‑value invoices, and some exempt transactions.
In this case, the validation model is based on a post‑audit approach, which means:
- Invoices do not pass through any government platform before being sent.
- There is no prior automatic validation; each company is responsible for issuing and receiving compliant invoices.
- Documentation must be kept intact, authentic and readable for possible future checks.
- The tax authorities may conduct subsequent audits to verify compliance.
This model offers flexibility, but also means that companies must have:
- Systems capable of issuing and receiving structured formats according to EN 16931.
- Robust internal processes to guarantee document quality.
- Secure archiving methods to demonstrate compliance in case of inspection.
In summary, there is no State validation at the time of sending; compliance relies entirely on the company.
E‑invoicing timeline in Germany
The planned schedule for the entry into force of e‑invoicing is as follows:
From 01/01/2025 – Already in force.
Companies must be able to receive structured e‑invoices (EN 16931). Suppliers may continue sending paper or PDF invoices only if the recipient agrees, while issuing e‑invoices does not require the recipient’s consent.
From 01/01/2027 – Companies with annual turnover above €800,000.
Companies exceeding €800,000 in annual turnover must issue structured e‑invoices. Invoices exchanged via direct system‑to‑system connections will remain valid as long as they meet the standard and both parties agree.
Until 31/12/2027 – Companies with annual turnover of €800,000 or below.
From 01/01/2028 – All companies.
The obligation extends to all companies, regardless of size. This marks the end of paper and non‑structured PDF, and the mandatory issuance of structured e‑invoices.
Around 2030.
Germany will introduce a transactional e‑reporting system, aligned with the European ViDA initiative.
