Germany: New Timeline in the Implementation of the European Directive on Public Sector e-Invoicing

Germany sets a new timetable for the implementation of the European Directive on electronic invoicing in the public sector.

European Directive 2014/55/EU calls on all member-state government agencies to be able to receive and manage electronic invoices in accordance with the standard specified by the European Committee for Standardization (CEN), 434 EU NORM 16931.

The use of e-invoicing in public procurement has become an EU digital transformation priority. The aim of these policies is to promote cross-border transactions among member states through a common e-invoicing standard that ensures security in business operations, streamlines administrative processes, and reduces the environmental footprint.

To deliver on the Directive, Germany, like the other EU member states, must transpose the European regulation by drafting domestic laws.  The German government enacted the E-Rechnungs-Gesetznational law and the E-Rechnungsverordnung legislative decree to that end.

When publication of the European invoicing standard was pushed back from 27 May 2017 to 18 October 2017, the European Parliament awarded an extension to the deadlines. The extension has been included in the domestic laws of the countries that have sought it, including Germany. This means the timeline for the application of B2G e-invoicing in Germany is now:

• 04/18/2019: B2G e-invoicing mandatory for receiving at national level.
• 04/18/2020: B2G e-invoicing mandatory for receiving at regional and communal level.
• 11/27/2020: B2G e-invoicing mandatory for sending at federal level.

This means that central government administrations have had to receive and manage e-invoices since last April.

Furthermore, by 18 April 2020 the 16 federal states, or Länder, in the German Federal Republic must have made their transpositions, as the German e-invoicing law E-Rechnungs-Gesetz authorizes them to enact their own transposition decrees.

Finally, suppliers to the public administration at the federal level will be required to issue invoices electronically by 27 November 2020.

B2G e-invoicing status at the national level in Germany

For now, as we saw earlier, central government agencies have been obliged to receive electronic invoices since 18 April this year.

In terms of the e-invoicing model at the central level, Legislative Decree E-Rechnungsverordnung has created the Koordinierungstelle für IT-Standards (KoSIT) institution, responsible for creating a standardized invoice that meets EN 16931 requirements. The e-invoice specifications are set out in the Core Invoice User Specification (CIUS).

The features of the CIUS-defined e-invoice are as follows:

• XRechnung standard
• OASIS UBL 2.1 syntax

The accepted communications are:

• Manual
• Email
• De-Mail
• WebService
• PEPPOL

The government has also created a national central invoice receiving platform called Zentrale Rechnungseingangsplattform des Bundes (ZRE). The platform will be the intermediary between suppliers and the central administration.

Communications via the European PEPPOL (Pan-European Public Procurement Online) infrastructure are not yet operative. The authority responsible for the PEPPOL network in Germany is KoSIT.

B2G e-invoicing status at the regional level in Germany

Each Land must publish its own transposition of the European Directive via a decree-law regulating communication systems, formats, and entry points for e-invoicing with regional and communal public administrations.

The final deadline for publishing these decrees is 18 April 2020. If the transposition has not been done by then, Germany could be disciplined by the European Union.

The federal states can choose whether to follow the CIUS model or prepare their own e-invoicing standard. They are also free to choose whether they want to leverage the central government’s ZRE platform or use a different system.

The only requirement on the Länder is that if they roll out their own web service they must offer a PEPPOL connection, too.

For now only three of the 16 states have published decree-laws regulating e-invoicing. Read all the details on e-invoicing implementation status in each German federal state.

EDICOM e-Invoicing platform

The German government has not recommended or defined any particular e-invoicing solution. This means that public administrations and suppliers are free to retain the platform that best adapts to their needs.

The EDICOM e-Invoicing platform is multi-standard and can transform any documents into the UBL, XRechnung, or ZUGFeRD standards defined by the German authorities.

Plus, EDICOM is certified as a PEPPOL Access Point, guaranteeing connection not only with German government agencies but any public administration in Europe.

EDICOM stands committed to e-procurement and e-invoicing progress worldwide and has been a member of the German e-invoicing association VeR (Verband elektronischer Rechnung) since 2018, and is part of GSI Germany.

EDICOM coordinates HOSP&INVOICE project (Action No: 2017-EU-IA-0146)