Electronic invoicing obligations for German businesses to public administration

^{This article was last updated on October 2, 2025, to reflect the successful completion of the consolidation of the ZRE and OZG-RE invoice submission platforms.}

Electronic invoicing is becoming increasingly important in Germany. While the federal government has mandated business-to-government (B2G) e-invoicing for its suppliers since November 2020, in compliance with EU Directive 2014/55/EU, the landscape of e-invoicing in Germany involves varying state-level requirements, specific formats, and upcoming business-to-business (B2B) obligations.

‍While the federal mandate establishes a baseline for electronic invoicing (e-invoicing) in business-to-government (B2G) transactions, Germany’s federal states (“Bundesländer”) have their own e-invoicing regulations, leading to varying requirements for suppliers of state and local public administration bodies. Some states, such as Hamburg and Saarland, implemented e-invoicing obligations in 2022, while others have, to this date, still not yet mandated e-invoicing with all their suppliers.

‍^{Suppliers should be aware that specific e-invoicing requirements are determined by the laws of each individual state. Further information is provided here (in German only) by the Coordination Office for IT Standards (KoSIT). We recommend contacting the relevant state administration or your government customer directly to confirm specific regulations or other details, such as the buyer reference (the so-called “Leitweg-ID”).}

‍Take a look at the nuances of Germany’s B2G e-invoicing mandates, the formats involved, and the country’s move towards B2B regulations as well.

What constitutes an e-invoice

‍According to Germany’s Ordinance on Electronic Invoicing in Federal Public Procurement (E-Rechnungsverordnung, or short, ERechV), invoices are considered electronic if they are issued, transmitted, and received in a structured electronic format that enables the document to be processed automatically and electronically.

‍Generally, the XRechnung standard, Germany's local standard and an implementation of the European standard for electronic invoicing (EN 16931), in its most current version, must be used for B2G e-invoicing. However, another data exchange standard may be used if it also meets the requirements of EN 16931 (e.g., ZUGFeRD version 2.0 or later in the XRECHNUNG profile).

‍In addition to the specifications outlined in the European or XRechnung standards, Germany’s federal states may impose further requirements on local businesses. Alongside these specifications, businesses must also consider any additional requirements set out by the federal or state government.

Who has to send electronic invoices in federal procurement (B2G)?

‍The E-Invoicing Ordinance (ERechV), adopted on 6 September 2017, mandates the use of electronic invoicing in federal public procurement (B2G) and transposes EU Directive 2014/55/EU into German federal law.

‍Here's a timeline of key implementation dates:

• November 27, 2018: Supreme federal authorities and federal constitutional bodies were required to accept and process e-invoices in the XRechnung format.

• November 27, 2019: All other federal administrative authorities were required to accept and process e-invoices.

• November 27, 2020: All suppliers to federal contracting authorities became obligated to transmit e-invoices. However, direct orders with a net value of up to €1,000 are exempt (see Section 3, Subsection 3 of the ERechV for all exceptions).

‍In essence, the ERechV requires the federal administration to receive electronic invoices and the suppliers and service providers of the federal government to send electronic invoices for public contracts.

What format is required for B2G transactions?

‍For B2G e-invoicing in Germany, the primary accepted format is XRechnung. This is a local German implementation of the European standard for electronic invoicing. XRechnung, which supports both CII (Cross-Industry Invoice) and UBL (Universal Business Language) as XML-based syntax, is designed to ensure machine-readability and seamless integration into processing systems and, while originally designed to cater specifically to B2G needs, is evolving to support broader B2B and digital reporting requirements.

While XRechnung is the primary standard, ZUGFeRD (Central User Guide of the Forum for Electronic Invoices in Germany) - technically identical to France’s Factur-X - is also accepted under certain conditions. Introduced in 2013, ZUGFeRD provides a hybrid format using both a PDF/A-3 file (human-readable) and an embedded XML file (machine-readable) using the CII syntax, and is particularly widely used in B2B contexts. Specifically, ZUGFeRD version 2.0 or later in an EN 16931-compliant profile, such as EN 16931/Comfort or XRECHNUNG profile, is an acceptable B2G alternative to XRechnung. Please note that the Minimum, Basic WL, and Basic profiles are still not sufficient for B2G use.

Additionally, Peppol BIS Billing 3.0 is accepted for invoices from abroad to German public authorities.

Update (2026): Guidance and future evolution of XRechnung

In March 2026, the German Federal Chamber of Tax Consultants (BStBK) published an updated FAQ on electronic invoicing, providing practical guidance on structured e-invoices compliant with EN 16931, including XRechnung and ZUGFeRD (from version 2.0 onwards). The guidance highlights validation requirements, VAT-relevant data checks, and integration into accounting workflows. It also reinforces archiving in line with GoBD, the German standard for digital record-keeping and audit, requiring that structured invoice data remains unchanged, machine-readable, and accessible for audit purposes.

In addition, the Coordination Office for IT Standards, responsible for maintaining the XRechnung standard and the XRechnung extension, KoSIT, has introduced a roadmap for XRechnung 4.0, indicating a broader evolution of the standard beyond B2G use cases to support B2B scenarios and future Digital Reporting Requirements (DRR) under ViDA.

Germany's federal e-invoicing platform: OZG-RE

‍The German federal administration previously utilized two main platforms to receive electronic invoices: the Zentrale Rechnungseingangsplattform des Bundes (Central Invoice Submission Platform, short ZRE) and the Onlinezugangsgesetz-konforme Rechnungseingangsplattform (Onlinezugangsgesetz-konforme Rechnungseingangsplattform or Online Access Act-compliant Invoice Submission, short OZG-RE).

‍However, the Federal Ministry of the Interior and Homeland Security (BMI) and the Federal Ministry of Finance (BMF) successfully completed the consolidation of these platforms on September 19, 2025. The ZRE has been shut down, and the OZG-RE is now the sole federal platform for submitting e-invoices to the entire federal administration (including the former ZRE users of the direct federal administration and the former OZG-RE users of the indirect federal administration and cooperating federal states).

This consolidation simplifies the process for suppliers by creating a unified access point. The OZG-RE, which can be accessed via the ELSTER-tax-software-based “Mein Unternehmenskonto” (company account), now handles the electronic invoice submission for over 170 institutions of the indirect federal administration and currently five federal states, in addition to the entire direct federal administration. Suppliers can continue to use the OZG-RE registration portal.

Data retention and compliance with Germany’s GoBD

‍Beyond the formatting and transmission of e-invoices, businesses must adhere to the German “Principles for properly maintaining, keeping and safeguarding books, records and documents in electronic form as well as for data access” (Grundsätze zur ordnungsmäßigen Führung und Aufbewahrung von Büchern, Aufzeichnungen und Unterlagen in elektronischer Form sowie zum Datenzugriff, or short, GoBD). These principles, in their regularly revised iterations, regulate the proper storage of electronic records, including e-invoices.

‍If requested by the tax authorities, data subject to recording and retention obligations, as well as the structural information necessary for the evaluation of the data, must be provided by the audited company in a machine-readable format. All information substantiating the invoice, including structural data, must be retained in its original format. For electronic invoices, this means that the original electronic format must be preserved.

The introduction of B2B e-invoicing

‍Germany has approved the Growth Opportunities Act (“Wachstumschancengesetz”), which includes the mandatory B2B e-invoicing regulation. This act was approved by the German Bundestag on November 17, 2023, and by the Bundesrat on March 22, 2024.

‍Here's a breakdown of the key implementation dates and requirements:

• Since January 1, 2025: All businesses must be capable of receiving e-invoices in the EN 16931 standard. Buyer consent is not needed for sending e-invoices in this format.

• Until December 31, 2026: Paper invoices and non-EN 16931 compliant e-invoices are still allowed, but only with the recipient's consent.

• From January 1, 2027: Businesses with a previous year's (2026) turnover of EUR 800,000 or more must issue e-invoices in EN 16931 or other agreed electronic formats where VAT information can be accurately extracted. EDI remains permitted provided that the VAT information can be extracted in EN 16931. For businesses in scope at this time, paper invoices will no longer be compliant.

• From January 1, 2028: The obligation to issue e-invoices is extended to all businesses. EDI remains permitted under the aforementioned conditions.

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E-invoices must be in a structured electronic format, such as XRechnung or ZUGFeRD. Formats like PDFs or text emails will not be considered compliant.

‍For the latest updates and further details, take a look at Germany’s e-invoicing regulations.

Ensuring your compliance with Banqup Group

‍Working with Banqup's e-invoicing solution provides your business with reassurance and peace of mind. Our solution is already tax and e-invoicing compliant in over 60 countries around the globe. We track daily regulation changes and adapt our solutions accordingly, so that your business remains compliant, without needing the expertise of e-invoicing experts.

‍To start your journey and ensure an easy transition to Banqup Group’s solutions, contact a member of our local German team to discuss your e-invoicing and compliance needs and get tailored guidance. For all the latest compliance news and updates, be sure to subscribe to our newsletter and follow us on LinkedIn.