VeR expands the conversation around B2B e-invoicing
VeR’s public events widen the discussion about B2B e‑invoicing as a driver for digitalization across the German economy
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E-Invoicing in Germany:
B2G & 2025-2028 B2B Mandate
Last update: 2026, October 4
Summary
Germany is implementing a B2B e-invoicing mandate between 2025 and 2028, requiring businesses to exchange EN 16931-compliant invoices without imposing a specific transmission method. B2G e-invoicing is also mandatory, but follows a more fragmented framework, with requirements varying between the federal government and the different states.
B2G Transactions
E-invoicing accepted everywhere, mandatory in some states
All German public entities have accepted EN 16931-compliant electronic invoices since 2020. The B2G framework remains fragmented, with platforms, transmission methods and supplier obligations varying by recipient and state.
B2B Transactions
Mandatory e-invoicing acceptance, soon mandatory issuance
All companies in Germany must be able to receive EN 16931-compliant electronic invoices since 2025. Sending e-invoices gradually becomes mandatory from the beginning of 2027 and 2028, respectively.
There is no mandatory transmission method, and companies are free to use the solution of their choice, such as Peppol, direct connections or even email.
B2C Transactions
No e-invoicing obligation
No e-invoicing or e-reporting obligation applies to business-to-consumer transactions in Germany.
Table of Contents
What the Law Says
B2G E-Invoicing
All public administrations in Germany accept electronic invoices compliant with the European Norm (EN 16931).
This means that any supplier to the public sector is allowed to send electronic invoices to any public entity in the country. Additionally, depending on the target public administration, the use of e-invoicing may be mandatory, as is the case since November 2020 at the federal level under the E-Invoicing Ordinance (ERechV) [↗︎].
In summary:
- E-invoicing is mandatory for suppliers: federal-level administrations and state-level administrations in seven states (Bremen, Hamburg, Baden-Württemberg, Saarland, Rheinland-Pfalz, Mecklenburg-Vorpommern and Hessen).
- E-invoicing is available but optional: state-level administrations in nine states (Bayern, Berlin, Brandenburg, Niedersachsen, Nordrhein-Westfalen, Sachsen, Sachsen-Anhalt, Schleswig-Holstein and Thüringen), as well as local-level administrations (municipalities) throughout the country.
No invoice format is imposed by the mandate. Invoice formats generally used in Germany include XRechnung, ZUGFeRD and Peppol BIS Billing 3.0.
Similarly, there is no national central platform or obligation to use the Peppol network to address German public entities. The method for sending an electronic invoice varies greatly depending on the type of public recipient (federal, state or local), the state and the recipient’s capabilities. Solutions can range from the OZG-RE platform, used by many public administrations in several states, to email.
A few further exceptions remain, for example for invoices below certain thresholds or for confidentiality reasons, and will disappear over time.
Invoices must generally be archived for eight years. This period was reduced from ten years on January 1, 2025, although many other financial documents must still be retained for ten years.
B2B E-Invoicing
Germany is implementing a B2B e-invoicing mandate in stages: all businesses have been required to receive e-invoices since 2025, while mandatory issuance will follow in 2027 or 2028, depending on company size.
The mandate was introduced in March 2024 through the Growth Opportunities Act (Wachstumschancengesetz) [↗︎]. It states that, since January 1, 2025, all companies must be able to receive electronic invoices.
Until the end of 2026, domestic invoices between private companies may still be exchanged in mutually agreed formats, ranging from paper and unstructured PDF invoices to hybrid formats such as ZUGFeRD (a PDF including an embedded XML file), as well as fully structured EDIFACT and XML-based formats, provided that they can be made human-readable in the event of an audit.
Electronic B2B invoice sending then becomes mandatory through a phased rollout:
- January 1, 2027: large and medium-sized companies (with previous-year turnover above €800,000) must send e-invoices.
- January 1, 2028: all companies must send e-invoices.
There are, however, several exceptions to mandatory issuance, as listed in the German Ministry of Finance’s official e-invoicing FAQ [↗︎]. Most notably, sending electronic invoices is not mandatory, although it remains permitted, for small-value invoices of up to €250 and for invoices issued by businesses benefiting from the small-business VAT exemption (Kleinunternehmerregelung), generally applicable where annual turnover does not exceed €25,000.
These exceptions apply only to the obligation to issue electronic invoices: businesses may still issue them voluntarily, and all German businesses must in any case be able to receive e-invoices.
The B2B e-invoicing mandate is relatively concise: it requires businesses to send and receive electronic invoices compliant with the European Norm (EN) 16931 in its official syntaxes, UBL and CII XML. Other formats are possible if both parties agree and the same information can subsequently be extracted.
As no transmission method is specified by the mandate, trading partners are free to agree on any delivery method, including decentralised models such as the Peppol network. However, because both parties must support the same method, many businesses may choose the simplest common option and end up exchanging electronic invoices by email.
Invoices must generally be archived for eight years. This period was reduced from ten years on January 1, 2025, although many other financial documents must still be retained for ten years.
B2C E-Invoicing
Germany does not have a B2C e-invoicing or e-reporting mandate.
Businesses may continue to issue business-to-consumer invoices and receipts through their usual channels, including paper invoices, PDF invoices sent by email, and printed receipts.
Timeline
B2G E-Invoicing Mandate
Almost all public bodies are required to accept electronic invoices.
Federal-level and some state-level administrations even make e-invoicing mandatory.
B2B E-Invoicing Mandate - Mandatory Acceptance
All German companies are required to accept electronic invoices compliant with the EN 16931
B2B E-Invoicing Mandate - Large Companies
Larger companies (turnover > 800K€) must send electronic invoices compliant with the EN 16931, or agree with their customer on a mutual format & transmission method.
B2B E-Invoicing Mandate - All Companies
All companies must send electronic invoices compliant with the EN 16931 official formats, or agree with their customer on a mutual format & transmission method
Latest E-Invoicing News in Germany
XRechnung 4.0 draft published: preparing for EN16931:2026 adoption
In a practical effort to support speedy implementation of upcoming EN16931-1:2026, Germany publishes an early draft of "XRechnung 4.0".
E-Rechnungs-Gipfel Frankfurt – October 26-28, 2026
2 months before Germany’s e-invoicing mandate, this conference offers an opportunity to meet experts, prepare, and fine-tune implementations.
Technical Details (B2G)
The German B2G mandate that took effect in November 2020 requires all German public administrations to accept electronic invoices in the formats listed below, all compliant with the European Norm (EN) 16931.
As mentioned above, it may or may not be mandatory for suppliers to send e-invoices: it depends on the target public administration. For those where e-invoicing is not mandatory, suppliers can keep sending paper-based invoices or simple PDFs.
Electronic Invoicing
Public administrations generally offer several electronic invoice formats:
- XRechnung: XML-based national invoice standard. It is part of the broader “XEinkauf” family of standards and maintained by the German Coordination Office for IT Standards (KoSIT) in Unified Business Language (UBL) and CII schemata
- Peppol BIS 3.0: XML UBL-based format used as a standard for all transactions on the Peppol network
- ZUGFeRD: hybrid format that combines PDF for human readability with XML using the Cross-Industry Invoice (CII) schema for machine-readable data (actually, the XML CII is embedded inside a PDF/A3)
B2G invoices must include a Leitweg-ID, an official identifier within German public administrations. The Leitweg-ID is used to route the invoices properly to their specific recipient within the public administration. Some partial lists of Leitweg-IDs are publicly available but no central directory is maintained, reflecting the German de-central administration. As a general rule, the Leitweg-ID should be given in the tender or order document; usage in practical life varies widely [↗︎], though.
Leitweg-IDs follow a simple, standardized syntax with the first 2 digits denoting the federal level (99) or state (01-16). Subsequent digits may represent the district, county and municipality respectively, followed by an alpha-numeric address code (up to 30 places). The Leitweg-ID is completed by a 2-digit checksum. The Leitweg-ID Format-Spezifikation (V2.0.2 – DE Only) [↗︎] is published as an XEinkauf document [↗︎].
Portals (or Lack Thereof)
Implementation of the B2G e-invoicing mandate varies significantly across federal levels, the 16 states and their 10,000+ municipalities. Most use a portal, through which suppliers can submit invoices using interactive web forms, manual file uploads, email or automated submission via the Peppol network.
Federal-level public administrations fall into two main groups, depending on their use of portals:
- The Online Access Act-compliant Invoice Submission (OZG-RE) portal must be used to transmit invoices to federal-level administrations, including “direct federal” administrations using Leitweg-IDs starting with 991 and “indirect federal” administrations identified with Leitweg-IDs starting with 992.
- There is no central point of entry for many other public administrations or companies owned by the federal government. These use Leitweg-IDs starting with 993, such as Deutsche Flugsicherung or public health insurers. Suppliers must ask each recipient directly how it wishes to receive electronic invoices: some may prefer Peppol, while others may prefer email.
Historically, the Central Invoice Submission (ZRE) portal was used to transmit invoices to “direct federal” administrations, serving Leitweg-IDs starting with 991. All ZRE recipients migrated to the OZG-RE portal when the migration was completed in September 2025 [↗︎], making OZG-RE the sole federal submission portal for recipients that previously used ZRE.
Regarding the different states and their local administrations:
- Five states also use the OZG-RE portal: Berlin, Brandenburg, Mecklenburg-Vorpommern, Sachsen and Thüringen.
- Nine states have separate portals with similar features: Baden-Württemberg, Bremen, Hamburg, Niedersachsen, Nordrhein-Westfalen, Rheinland-Pfalz, Saarland, Sachsen-Anhalt and Schleswig-Holstein.
- Two states do not use a central platform: Bayern and Hessen. Both are planning to provide options, with Bayern committed to using OZG-RE [↗︎]. For the time being, suppliers should ask their public buyers directly how they wish to receive e-invoices.
In March 2026, the IT-Planungsrat decided to consolidate public-administration platforms [↗︎] and directed the Federal Ministry of the Interior and the Office for Public Purchasing (Beschaffungsamt) to establish a project group and prepare an implementation plan.
E-Invoicing Overview (B2G)
Federal-Level Administrations | Central E-Invoicing Portal | Leitweg-ID | |
|---|---|---|---|
Direct Administrations | Mandatory | Yes (OZG-RE since 2025) | 991- |
Indirect Administrations | Mandatory | Yes (OZG-RE) | 992- |
Other Federal Administrations | Mandatory | No | 993- |
Additional information available on the official e-rechnung-bund.de website [↗︎].
State-Level Administrations | Local-Level Administrations | Central E-Invoicing Portal | |
|---|---|---|---|
Baden-Württemberg | Mandatory | Accepted | Yes |
Bayern | Accepted | Accepted | Soon (OZG-RE) |
Berlin | Accepted | Accepted | Yes (OZG-RE) |
Brandenburg | Accepted | Accepted | Yes (OZG-RE) |
Bremen | Mandatory | Accepted | Yes |
Hamburg | Mandatory | Accepted | Yes |
Hessen | Mandatory | Accepted | No |
Niedersachsen | Accepted | Accepted | Yes |
Mecklenburg-Vorpommern | Mandatory | Accepted | Yes (OZG-RE) |
Nordrhein-Westfalen | Accepted | Accepted | Yes |
Rheinland-Pfalz | Mandatory | Accepted | Yes |
Saarland | Mandatory | Accepted | Yes |
Sachsen | Accepted | Accepted | Yes (OZG-RE) |
Sachsen-Anhalt | Accepted | Accepted | Yes |
Schleswig-Holstein | Accepted | Accepted | Yes |
Thüringen | Accepted | Accepted | Yes (OZG-RE) |
Technical Details (B2B)
Current Situation (Until End 2026)
Any transmission channel or format is valid as long as it is mutually agreed by both parties and there is a complete business audit trail:
- Paper-based invoices
- ZUGFeRD-PDF including an embedded XML file
- EDIFACT and many more formats are widely used, often in the context of an “EDI Model Agreement” (94/820/EC of 19.10.1994 [↗︎])
Private businesses can also use the XRechnung format without having a Leitweg-ID, as those are only used for public recipients. Instead, they use other available identifiers such as their VAT number as assigned by the tax administration or GLNs registered with GS1.
Implementing the E-Invoicing Mandate (Starting 2025)
Electronic B2B invoicing gradually becomes mandatory over a 3-year transition period (1/1/2025 – 1/1/2028). And this mandate’s requirements are very succinct. In fact, for the content there’s only one: invoice information needs to comply with the European Norm (EN) 16931.
For invoice-sending, private companies have the choice between:
- one of the recommended XML formats (EN 16931 compliant): ZuGFeRD, XRechnung, Peppol BIS 3.0 (see more about these formats in the Technical Details (B2G) section)
- additionally, any other mutually-agreed EDI format, as long as all EN-16931-required invoice information can be extracted.
Conversely, for inbound invoices, all approved EN-16931-compliant syntaxes will have to be accepted.
Most companies with EDI already in place will naturally opt for the latter option, as it will allow them to keep operating those existing EDI connections. However, it also means that those EDI connections will need to be upgraded until January 1st, 2028 at the latest to allow the EN 16931 compatible invoice content to be extracted.
However, the German B2B e-invoicing mandate doesn’t require any central platform or transmission technology, and companies will be free to choose the solution that best fits both parties’ needs (Peppol network, traditional EDI connections, even email, …) as long as they can document a complete business audit trail later.
The Invoicing Hub Word
Germany
German B2G e-invoicing reflects the complexities of the decentralised federal structure of the public administration, leading to many different cases, timelines and exceptions.
Still, all public recipients have to accept electronic invoices. The XRechnung and ZuGFeRD formats used domestically are actively developed to better conform to international standards, and accommodate the needs & constraints of both large enterprises & SMEs. Similarly, more and more German public administrations become reachable via Peppol, but many others still prefer a good old email.
B2G e-invoicing in Germany is therefore more complex than it feels necessary, although unification is expected to increase as yet more mandates close remaining gaps over the next few years.
The B2B mandate follows the same approach as it describes the “what” (exchange EN16931-compliant e-invoices) but doesn’t say a word about the “how” (no central platform and unified transmission technology).
On one side, it will give flexibility to companies to implement the solution that best suits them which will boost business efficiency across the entire German economy. But on the other side, it will lead to a lot of complexity with a very disparate e-invoicing landscape and a multitude of different implementation types.
Making the correct choices will be a challenge and the choice of a proper solution will be the key to success for all German companies.
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Official Resources [↗︎]
Public entity coordinating the use of standards in the public administration
Official guidance from the Federal Ministry of Finance on the German B2B mandate, formats, reception, transitional periods and archiving
Information on B2G e-invoicing by the Ministry of the Interior (BMI)
Online portal for B2G e-invoicing to Federal indirect administration and several states
Specifications and artifacts for download
Published by the FeRD (Forum on e-Invoicing in Germany)
The Peppol Authority for Germany is run by federal mandate at the Koordinierungsstelle für IT-Standards (KoSIT) in Bremen, which is part of the “XStandards Einkauf” (Public Purchasing Standards) team.
Completed status of the Legislative process surrounding the e-invoicing mandate
Related Resources
Every layer of e-invoicing validation checks that an invoice is well-formed. None checks whether the tax on it is correct.
A Comarch webinar featuring PwC, exploring real-world implementation lessons, structural compliance friction, and global mandates.
The billentis 2026 report "Riding the Tornado" features key insights into global e-invoicing and compliance from leading experts.
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