E-invoicing in Germany: requirements, formats, and timeline

Germany's transition to mandatory electronic invoicing is one of the largest such reforms in Europe. It is also one of the more pragmatic ones: there is no single national platform, no mandatory clearance, and no universal Italian-style real-time reporting. The German approach is to mandate the format of the invoice and leave transmission and processing largely to the contracting parties.

Legal framework

The relevant law is §14 of the Umsatzsteuergesetz (UStG), as amended by the Wachstumschancengesetz of March 2024. The amendment redefines the Rechnung for VAT purposes and makes the electronic invoice the legal default for B2B transactions between domestic German businesses. A paper invoice (or unstructured PDF) becomes a special case requiring the recipient's consent — and even then is no longer considered a Rechnung in the sense of §14 UStG once the transition phases conclude.

The supporting administrative guidance comes from the BMF (Bundesministerium der Finanzen), which has published a series of clarification letters since 2024 explaining how the new rules interact with existing provisions on input VAT deduction, corrections, and document retention.

Timeline

The mandate phases in over four years:

The B2C invoicing rules are unchanged. There is no consumer-facing e-invoicing mandate.

Accepted formats

Two formats dominate:

Both formats satisfy §14 UStG. The distinction matters in practice rather than in law; see XRechnung vs ZUGFeRD for the trade-offs.

PEPPOL BIS Billing 3.0 is also accepted in Germany — the German PEPPOL infrastructure (run by KoSIT and the federal government) treats it as equivalent to XRechnung for receiving purposes — but it is not the dominant choice for purely domestic German invoicing.

B2G transmission

For invoices to public administration, transmission is constrained. Federal authorities receive through the Zentrale Rechnungseingangsplattform (ZRE). State authorities use either the OZG-RE platform (a shared system for several länder) or their own dedicated portals. Each portal accepts uploads through a web form or, for higher volumes, programmatic submission via PEPPOL or direct integration.

Every B2G invoice must carry a Leitweg-ID in the buyer reference field (BT-10). The Leitweg-ID is a structured routing identifier that identifies the receiving sub-unit; the supplier obtains it from the public-sector buyer at the time of contract or order. Without a valid Leitweg-ID the invoice cannot be routed and will be rejected at the portal.

B2B transmission

There is no German equivalent of Italy's SdI or France's PPF. B2B invoices are transmitted by whatever channel the buyer and seller agree on: email attachment, SFTP, a customer's upload portal, an EDI link, the PEPPOL network, or a third-party service provider. The legal requirement is that the file is an EN 16931-compliant electronic invoice; how it gets from one to the other is a private-law matter.

This is one of the German reform's distinguishing features. It avoids building a central state platform — and the associated cost, latency, and political risk — at the price of leaving every business to coordinate transmission with every counterparty individually. For organisations with many small counterparties, this can be operationally heavier than a centralised system would be.

Archival

Accounting records, including invoices, must be retained for eight years under §147 of the Abgabenordnung (AO). This was shortened from ten years by the Bürokratieentlastungsgesetz IV, effective for records whose retention period had not yet expired by 1 January 2025. Electronic invoices are subject to the additional GoBD requirements (Grundsätze zur ordnungsmäßigen Führung und Aufbewahrung von Büchern, Aufzeichnungen und Unterlagen in elektronischer Form sowie zum Datenzugriff), which require:

For ZUGFeRD, both the PDF and the embedded XML must be retained — they are part of the same artefact and cannot be separated without losing legal completeness.

Validation and the tax authority's position

The German tax administration does not operate a central validator. Compliance is the issuer's responsibility, and a validation failure discovered after the fact may threaten the receiver's input VAT deduction (the EuGH Senatex judgement, C-518/14, allows retroactive correction in many cases, but the safest course is still to issue a compliant invoice from the start).

The official validator for XRechnung is published by KoSIT. Our validator bundles the same schematron rules and is suitable for pre-issuance and pre-acceptance checks. Both produce equivalent results for any well-formed file.

Practical advice

For a German business preparing for the 2025–2028 transition, three things matter most:

  1. Be receiving-capable by January 2025. This is a legal requirement, not a recommendation. The threshold is low — receiving means accepting an EN 16931 file by some agreed channel and storing it in compliance with GoBD. It does not require full AP automation.
  2. Pick a format and stick to it for issuance. The choice between XRechnung and ZUGFeRD should be made once, deliberately, based on what your receivers actually need and what your producing system can output cleanly.
  3. Treat the Leitweg-ID as a contract artefact. For public-sector customers, the Leitweg-ID belongs in the customer master record, not in a free-text field at invoice creation time. Getting this wrong is the most common cause of B2G invoice rejections.