PEPPOL IN EUROPE
E-Invoicing in Germany
In Germany, the e-invoicing topic is more complicated than in any other European country. This is because the different federal states (Länder) have enacted their own laws and regulations on e-invoicing. And those contain as many differences as similarities. In April 2023, the Ministry of Finance has published a B2B e-invoicing discussion paper, and the consultation ended in May 2023.
Here are the outlined implementation timelines:
- Starting on January 1, 2025, EN16931-compliant e-invoices have become standard in Germany.
- Companies must be ready to accept structured electronic invoices that adhere to the EN 16931 standard.
- Suppliers are permitted to issue paper invoices. For invoices in unstructured formats (such as PDF) and non-CEN-compliant EDI invoices, the buyer’s consent is required. However, these alternative formats will be progressively phased out according to the schedule detailed below.
On January 1, 2027, phase 2 of the gradual elimination of non-CEN-compliant invoices begins. Businesses with an annual turnover exceeding EUR 800,000 in the previous year will be prohibited from issuing invoices either on paper or in unstructured electronic formats, even with the buyer’s consent. On January 1, 2028, Phase 3 of the gradual elimination of non-CEN-compliant invoices takes effect:
- All other businesses will be restricted from issuing invoices on paper or in unstructured electronic formats, regardless of buyer’s consent.
- EDI e-invoices that do not comply with EN16931 will also be prohibited unless they are „interoperable” with the CEN norm.
It is hard to say what kind of model is going to be implemented in Germany, i.e., a central solution, as well as a decentralized (similar to PDP in France), which is currently being considered. The German Ministry assures that they aim to introduce one solution for both ViDA-connected intracommunity transactions reporting as well as for the national solution.
In contrast with B2B, there are rules for B2G e-invoicing in Germany. Applying EU directive 2014/55/EU, B2G e-invoicing became obligatory on November 27, 2020. The format for B2G invoices is called XRechnung, which is a semantic data model based on XML. It complies with the European standard EN 16931. This format is to be used when sending an invoice to a public authority in Germany. The public authorities are obliged to receive and process this format.
If someone needs to issue an invoice to an entity of the public sector, they have to decide whether this entity belongs to the federal administration directly or indirectly or if it is an authority of a German federal state. For direct federal administration, the invoice is to be submitted through the Zentrale Rechnungseingangsplattform or ZRE. For indirect federal ad-ministration, invoices should go through the Onlinezugangs-gesetz-konforme Rechnungseingangsplattform or OZG-RE. The latter is also used by some of the federal states as an invoicing portal (more on this later). Besides that, a minimum amount of EUR 1,000 for e-invoicing has been set. Invoices below that figure are not subject to e-invoicing.
The ZRE and the OZG-RE platforms enable the creation of an XRechnung. Besides that, it is possible to generate an XRechnung in other systems, such as an ERP system. It can then be uploaded to the respective platform. Another option would be to connect through an EDI service provider.
What is also important in B2G e-invoicing is the LeitwegID. This number identifies the invoice recipient (a public authority, a municipality, a ministry, or their departments). Before sending an invoice, the Leitweg-ID must be determined in order to ensure that the invoice reaches the proper recipient. If a company sends a lot of invoices in the XRechnung format, it is advisable to look for a service provider who can collect those invoices from the company’s IT system and transfer them to the recipients via EDI. Using such a service provider brings another advantage, offering data enrichment services or business data validation. Invoicing platforms such as ZRE or OZG-RE only check electronic invoices with regard to technical requirements, not for their business content.
