Return to mapElectronic invoicing in Germany
Germany is in the midst of a digital transformation of its tax and administrative processes, and electronic invoicing plays a central role in this evolution. Although its adoption was voluntary for many years, the German authorities have moved towards an increasingly standardized and automated environment, in line with the European digitization strategy and the upcoming implementation of the ViDA (VAT in the Digital Age) guidelines.
Features of B2B electronic invoicing in Germany
The Bundesministerium der Finanzen (BMF), the Federal Ministry of Finance, plays a central role in defining and implementing the legal framework for electronic invoicing in Germany. In collaboration with the Länder and the federal tax administration, the BMF has developed technical and legal guidelines that set standards for the issuance, receipt, and storage of electronic invoices.
One of the main recent milestones is the approval of the Wachstumschancengesetz (Growth Opportunities Act), adopted in March 2024. This law introduces mandatory electronic invoicing for domestic B2B transactions, establishing the technical conditions and implementation deadlines.
The BMF has also announced plans to create a national infrastructure for transmitting electronic invoices, which in the future will enable data to be automatically transmitted to the tax authorities, following models similar to those in Italy and France.
Mandatory Use
The BMF has proposed an implementation schedule that affects the receipt, issuance, and use of the different formats.
- 01/01/2025: All companies must be able to receive electronic invoices.
- 01/01/2027: Mandatory issuance of electronic invoices for companies with an annual turnover of more than 800,000 euros.
- 01/01/2028: All companies must send B2B electronic invoices.
Invoice formats
01/01/2025
- Paper
- Electronic invoice in accordance with regulation EN 16931, which defines the semantic model related to the data to be included in the invoice: Compatible national formats in Germany: XRechnung and ZugFeRD.
- Other formats (XML, EDIFACT, X12, etc.)
01/01/2027
- Paper: permitted under special conditions
- Electronic invoices in accordance with regulation EN 16931, which defines the semantic model related to the data to be included in the invoice: National formats compatible in Germany: XRechnung and ZugFeRD.
- Other formats (XML, EDIFACT, X12, etc.): permitted under special conditions
01/01/2028
- Electronic invoices in accordance with regulation EN 16931, which defines the semantic model related to the data to be included in the invoice: National formats compatible in Germany: XRechnung and ZugFeRD.
- Other formats (XML, EDIFACT, X12, etc.) provided they are compatible with the EN16931 format.
Electronic signature
In Germany, an electronic signature is not mandatory for an electronic invoice to be valid.
Storage
In terms of storage, electronic invoices must be kept for 8 years, plus an additional year if required for tax or accounting reasons (8 + 1 years in total). During this period, documents must be stored in accordance with German storage regulations known as GobD, ensuring the traceability, verifiability, and integrity of the stored documents.
Upcoming dates in Germany
Characteristics of B2G electronic invoicing in Germany
Germany implemented electronic invoicing in public administrations according to a schedule that made B2G invoicing mandatory in the federal states. The progress of electronic invoicing adoption depends on each federal state (Bundesland) issuing its legal decree, which sets out the rules for communication systems, formats, and entry points. The only universal requirement is that electronic invoicing must be accessible via Peppol in all cases.
The rollout of B2G (Business to Government) electronic invoicing in Germany has been carried out in phases:
• April 18, 2019: Mandatory acceptance of electronic invoices at the national level.
• April 18, 2020: Mandatory acceptance at the regional and local levels.
• November 27, 2020: Mandatory issuance of electronic invoices to the federal administration.
Mandatory compliance
The German federal law on electronic invoicing, E-Rechnungs-Gesetz, grants its federal states the power to enact their own transposition decrees.
The national process in Germany has run parallel to that of its 16 federal states, each with legislative autonomy to carry out its own transposition of the European directive.
Check the updated information on the status of B2G invoice implementation in the German states.
Invoice format
The electronic invoice format for the central government in Germany is defined in the Basic Specification for Invoice Users (CIUS). Two formats are accepted: the national ZUGFeRD and Peppol UBL, known as XRechnung.
Upcoming dates in Germany
Frequently asked questions about electronic invoicing in Germany
What is XRechnung?
XRechnung is one of the supported formats for electronic invoicing in Germany. This format is mandatory for central, regional, and local authorities. It is an XML document adapted to the requirements of the European Union.
What is ZUGFeRD?
ZUGFeRD (Zentraler User Guide des Forum elektronische Rechnung Deutschland) is one of the supported electronic invoice formats in Germany. It is a hybrid format consisting of an A3 PDF with embedded XML in accordance with the European standard.
What is OZG-RE?
The federal government's OZG-RE (Onlinezugangsgesetz-konforme Rechnungseingangsplattform) platform is a platform that suppliers and service providers can use to transmit electronic invoices to indirect federal administration organizations and cooperating federal states.
Does the new regulation also apply to international transactions?
Not immediately. For the time being, the electronic invoicing obligation applies only to domestic B2B transactions between companies based in Germany.
Cross-border transactions will continue to be regulated by the rules of the European VAT Directive and future developments of the ViDA project, which could introduce a harmonized electronic reporting system at the EU level.
What about simple paper or PDF invoices?
During the transition period (2025–2027), the exchange of invoices in PDF or other unstructured formats will continue to be accepted, but only if both parties agree. From 2028 onwards, only structured electronic invoices that comply with the EN 16931 standard will be accepted.
What requirements must storage in Germany meet to be GoBD-compliant?
When a system or process is said to be “GoBD-konform,” it means that it complies with these legal principles established by the Federal Ministry of Finance (BMF), ensuring that digital data such as electronic invoices, accounting records, and tax documents are managed and stored in a secure, complete, traceable, and accessible manner.
The purpose of GoBD is to ensure that all tax and accounting information:
- Is authentic and verifiable.
- Is not altered without leaving a trace (data integrity).
- Is legible and retrievable throughout the retention period (usually 10 years).
- Allows full and rapid access to the tax authorities in the event of an audit.
In other words, “GoBD-konform” storage ensures that electronic documents can serve as valid evidence before the Finanzamt (German tax authority).
Upcoming dates in Germany
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