In Germany, e-invoicing is currently required for B2G (Business-to-Government) transactions, and a B2B (Business-to-Business) mandate has also been proposed starting in 2025. Here’s what you should know about e-invoicing mandates in Germany.
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XRechnung: German B2G e-invoicing mandate
The German B2G e-Invoicing mandate is commonly referred as ‘XRechnung’. The first wave was targeted for the central government (aka Bund).
The XRechnung journey really started end of 2020. XRechnung is defined as a CIUS to the EN-16931 Core, as Version2 was to be used starting in January 2021.
Besides a number of content requirements, the public customer identification by a LeitwegID took some attention. A LeitwegID can be used for addressing as well as generic buyer reference, most of the time both correspond but in certain cases, the values differ.
Besides that, invoice delivery was the second point: if automated exchange was in scope (such as through web services), Peppol needed to be offered as a common denominator. But we have seen most attention going to portal platforms.
How to comply with Deutschland XRechnung
On the Bundes level, the government has prepared 2 portals:
Both these portals allow for manual upload as well as follow-up monitoring. They also provide a “robot” e-mail as well as a Peppol interface.
These portals and e-mail requirements are not designed for automation and are not service provider-friendly. For e-mail, the supplier needs to register and whitelist the e-Mail address they will be using for sending invoices. The Peppol gateway, however, fulfills these requirements.
Large buyers escape these flows: the entities belonging to the Deutsche Bahn have their own approach and are not connected to the portals nor addressable using Peppol.
Regional differences for B2G e-invoicing
Bremen is the first regional state that opened up for e-Invoicing using the zErika portal or Peppol delivery. In Bremen, the address for Peppol is distinct from the buyer reference to be used in the transaction.
Since 2022, The B2G mandate was extended to a number of states or regions (Länder), more specifically. Today although most of them accept XRechnung invoices through Peppol, there remain differences between states:
- A few of them do not offer Peppol as a possible channel to send invoices
- Some offer alternative channels such as email or web services
- Some accept a number of alternative formats such as ZUGFeRD
Germany proposes B2B e-invoicing mandate
In April 2023, the German Ministry of Finance requested consultation on a proposal to mandate e-invoicing for all business-to-business (B2B) transactions starting in 2025. This proposed requirement would be based on the European Commission’s Value Added Tax in the Digital Age (ViDA) framework, which is expected to mandate cross-border e-invoicing by 2027.
The e-invoicing mandate in Germany will be done in two steps: first a mandate to use electronic invoices between sellers and buyers will be introduced, and as a second step a proper CTC/Clearance regime will be put in place (i.e. invoices will need to be reported to the German tax administration).
The timeline for the first step is as follows:
- January 2025, all companies are required to be able to process inbound electronic invoices
- January 2027, large companies (>800k€ turnover) must send electronic invoices
- January 2028, companies with a turnover under 800k€ will be required to send electronic invoices
- Note that until January 2028, electronic invoices can still be sent using an EDI format; after that date, only en16931 invoices must be used
The timeline for the second phase – implementation of a CTC regime – remains to be defined.
Simplify German e-invoicing compliance with Axway
When you consider that all EU countries are anticipated to operate under the B2B e-invoicing standard by 2030, it’s important to consider an e-invoicing strategy that takes into account global standards – beyond individual country mandates.
Axway eInvoicing enables companies to comply with an evolving list of B2B and B2G invoicing requirements around the world. Fully integrated with existing e-invoicing regulations, this cloud-based solution allows for continuous compliance and the agility to meet diverse and evolving national and legal requirements, now and in the future.
Take control of your e-invoicing process to ensure not just global compliance but also maximized efficiency and cost reduction with a 100% digital solution.
Learn more about how Axway eInvoicing handles invoice processes in a global, standards-driven, and always up-to-date manner.