Germany plans to implement B2B e-invoicing by 2025

During the second part of 2023, the Bundesministerium der Finanzen released a discussion paper proposing the implementation of mandatory B2B e-invoicing and called for the repeal of Articles 218 and 232 of Directive 2006/112/EC. The paper refers to the e-invoicing concept as proposed by the European Commission's ViDA Project and EN 16931.

After many months of negotiations, B2B e-invoicing in Germany finally has a set launch date: 1 January 2025. 

The Growth Opportunities Act (Wachstumschancengesetz) has been approved by the Bundesrat, formalising the implementation of B2B e-invoicing. The timetable for implementation is as previously planned:

  • January 2025. Businesses must be prepared to receive structured e-invoices that comply with EN 16931 standards and, for the time being, suppliers will be able to continue issuing paper invoices. However, invoices in unstructured formats (such as PDF) and EDI invoices that do not comply with the EN standard will require the buyer's consent.
  • In January 2027, phase 1 will begin to gradually eliminate invoices that do not comply with standard EN 16931. Taxpayers with an annual turnover of more than €800,000 will be required to use B2B e-invoicing.
  • By January 2028, all companies must ensure that their e-invoices adhere to the EU structured standard. Additionally, B2B e-invoicing is now mandatory for all companies.

Background on B2G e-invoicing in Germany

As Germany is divided into a federal structure, the government and the 16 states had to pass their respective e-invoicing laws to implement Directive 2014/55/EU.

At the federal level, the B2G e-invoicing law came into force since 2017, while at the state level different laws have been passed.

With the publication of the e-Invoicing Act in April 2017 and the e-Invoicing Regulation in September 2017, all federal contracting authorities in Germany are obliged to receive and process e-invoices. The law applies exclusively to regulations for federal bodies.

State or local authorities need additional laws from the federal states, also called Länder. At the federal level, these supplementary laws turn the European Directive into legislation. Therefore, since 18 April 2020, state authorities have to accept e-invoices.

How was the B2G e-invoice implemented in Germany?

From 27 November 2018, federal state authorities are required to receive and process invoices electronically. A year later, on 27 November 2019, all subordinate institutions and sectoral contracting authorities at the federal level will also begin to process electronic invoices.

Finally, from 27 November 2020, all public contracting authorities of the federal administrations must issue and process electronic invoices.

What is the B2G e-invoicing model in Germany?

The e-invoicing model in Germany is decentralised. In the B2G context, issuing is mandatory for all suppliers of all federal and Bremen contracting authorities, while receiving is mandatory for all federal authorities of the central government as well as authorities of the Länder.

Although different e-invoicing platforms exist, Germany has implemented a unified routing system. This routing ID (Leitweg ID) enables the platform to transmit invoices to the public contracting authorities.

The Leitweg ID is a mandatory element in the XRechnung scheme, each ID is composed of a state code and a check digit, while government, district and municipality codes remain voluntary.

The Federal Central Invoice Receipt Platform (ZRE) requires companies to submit electronic invoices in the XRechnung format. This format is mandatory for issuing, processing, and accepting invoices by all central and state authorities in Bremen. Additionally, a second platform, OZG-RE, has been developed.

If automated data exchange is available for electronic invoice delivery, all federal and national authorities must use the PEPPOL network. To ensure that PEPPOL transactions can be carried out in Germany, economic operators must select a provider accredited by the PEPPOL Authority, as the XRechnung format is specific to Germany.

E-invoicing in Germany: Key features

Each federal state has the option to either use the standard CIUS model or create its own format for sending, receiving, and processing invoices to state authorities.

This allows for the flexibility of each state to choose between using the central government platform or developing its own platform for handling e-invoices.

The states that have developed their own platform are currently using it are:

  • Follow the local ErechVOBW regulations on in Baden-Württemberg.
  • Lower Saxony: Zentrale E-Poststelle. Follows the local regulation Niedersächsischen Verordnung über den elektronischen Rechnungsverkehr.
  • Bremen: zERIKA. Adhere to the regulations outlined in the local E-Rechnungs-VO.
  • Hamburg via the Elektronische Postselle portal.
  • North Rhine-Westphalia: vergabe.NRW. Folgt der örtlichen Regelung Verordnung zur Ausgestaltung des elektronischen Rechnungsverkehrs nach § 7a des E-Government-Gesetzes Nordrhein-Westfalen.
  • Rhineland-Palatinate: ZRE RLP (E-Rechnungsportal Rheinland-Pfalz).
  • Saxony Anhalt, via the E-Rechnungsportal portal.
  • Schleswig-Holstein. Follows the local regulation E-Rechnungsverordnung (ErechVO).

In Berlin, Brandenburg, Mecklenburg-Pomerania, Saxony and Thuringia, the central portal OZG-RE has been used. In Hessen, Bavaria and Saarland no central reception system has been set up.

SERES, an ideal partner for multi-country projects

To comply with international obligations, it is recommended to contract a global e-invoicing solution that is certified in all the countries where your company operates.

The SERES Multi-Country e-Invoicing solution offers several advantages for companies:

  • The solution meets all legal and technical requirements in each country where it is used. Electronic invoicing streamlines workflows between subsidiaries or companies located in different countries.
  • Our service provides a single point of collaboration for internal information exchange, with automatic integration and report generation.
  • Real-time visibility allows for efficient management of treasury, debts, and accounts payable by providing up-to-date information from all subsidiaries.
  • The global operator ensures automatic adaptation without the need for each subsidiary to adjust to a different provider. Additionally, a support and help service is available throughout the activation process.

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Key numbers

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+30 years

of experience
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+750 MM

€/year managed
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3 Millions

active users
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+1.000 M

documents/year exchanged
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connected companies
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countries with exchange

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