Digital Invoice Receipt in Germany and Across Europe

Regulations, Laws & Directives

In addition to German legislation at both federal and state level governing electronic invoicing for public administration, there is also a wide range of European frameworks shaping how electronic invoice exchange is implemented across member states.

With ongoing developments such as the European ViDA initiative, new national and international regulations continue to emerge. We will keep this section regularly updated to ensure you stay on top of the latest requirements and developments.

Legal Frameworks for eInvoicing in Europe

EU Directive 2014/55/EU

Validity: Published on April 16, 2014, and entered into force on May 26, 2014
Scope: Member states of the European Union, B2G
Origin: EU

Directive 2014/55/EU on electronic invoicing in public procurement was introduced to standardize electronic invoices across the EU and thereby facilitate their exchange within the EU. Public procurement processes were intended to become more efficient, transparent, and competitive, while administrative costs were to be reduced.

Public authorities in the EU were therefore required to accept and process electronic invoices. As a result, suppliers conducting business with public sector entities in the EU can now submit their invoices electronically – and in many cases are even required to do so.

Member states were deliberately granted a certain degree of flexibility. In Germany, for example, the federal legislative structure has led to a wide range of different interpretations of the “e-invoicing obligation” in the B2G sector. This is also reflected in the large number of different e-invoicing laws and regulations at the German state level.

The directive had to be transposed into national law in all EU member states by November 27, 2018 at the latest, through corresponding national laws and regulations.

European Standard on eInvoicing (EN): EN 16931

Validity: Published on June 28, 2017
Scope: Member states of the European Union, B2G
Origin: European Committee for Standardization (CEN), commissioned by the European Commission

The European standard EN 16931 defines the core elements of an electronic invoice in a semantic data model and thereby aims to enable the cross-border exchange of electronic invoice documents across Europe. The standard is complemented by industry- or country-specific extensions, known as Core Invoice Usage Specifications (CIUS).

The most well-known national “extension” of the European requirements in Germany is XRechnung. However, the German ZUGFeRD standard, in all versions from 2.0 onwards, also complies with the European requirements and is therefore suitable for exchanging electronic invoices in accordance with Directive 2014/55/EU.

Legal framework for e-invoicing in Germany

E-Invoicing Act

Validity: Entered into force on November 27, 2018
Scope: Federal level, B2G
Origin: Germany

With the E-Invoicing Act, a binding legal framework was established for the receipt and processing of electronic invoices by federal public authorities, which was incorporated, among other things, into the already existing E-Government Act. This implemented the requirements of Directive 2014/55/EU into national law at the federal level, which were later further specified in the Federal E-Invoicing Ordinance (ERechV).

Act to Promote Electronic Government (E-Government Act)

Validity: Entered into force on August 1, 2013
Scope: Federal level, B2G
Origin: Germany

The E-Government Act was introduced to promote and facilitate electronic communication between citizens, businesses, and public administration. From its initial version, it aimed to make administrative processes more efficient, faster, and more user-friendly. The Act is intended to drive the digitalization of public administration and thereby contribute to the modernization of public services.

With the amendments and additions introduced through the Federal E-Invoicing Act in 2018, the E-Government Act established the legal framework for electronic invoicing in the public sector in Germany.

Some key aspects related to e-invoicing within the E-Government Act include:

Electronic format: e-invoices must be submitted in a standardized, machine-readable format, facilitating automated processing and validation.
Access points: the Act provides for the establishment of central access points through which e-invoices can be transmitted to public authorities.
Obligation to accept: federal public authorities are required to accept and process e-invoices.

Important: the specific requirements and deadlines for implementing e-invoicing may vary depending on the federal state and authority due to Germany’s federal structure, as reflected in the numerous state-level regulations and laws on e-invoicing.

The E-Government Act forms the legal framework for the introduction of electronic invoicing in the public sector at the federal level, while the specific requirements and technical specifications are primarily defined in the Federal E-Invoicing Ordinance (ERechV).

E-Invoicing Ordinance (ERechV)

Validity: Entered into force on November 27, 2020
Scope: Federal level, B2G
Origin: Germany

According to the E-Invoicing Ordinance, invoice issuers are required to issue and transmit electronic invoices to federal invoice recipients. These recipients must receive electronic invoices via an administrative portal. In addition, invoice issuers and senders are expected to use the XRechnung data exchange standard, unless another standard also complies with the European norm.

Electronic invoices submitted to federal recipients must also include specific information such as the routing ID (Leitweg-ID), bank details, payment terms, and the contact information of the invoice issuer. Additional details, such as the supplier number and purchase order number, are also required if they were provided during the procurement process.

E-Invoicing Ordinance of Baden-Württemberg (ERechVOBW)

Validity: Entered into force on January 1, 2022
Scope: Baden-Württemberg, B2G
Origin: Baden-Württemberg

In Baden-Württemberg, the issuance and transmission of electronic invoices are generally mandatory when services are provided to public administration. However, this does not apply to invoices containing confidential information, to cash and immediate payments, or to amounts below EUR 1,000. In some cases, different rules may apply to municipalities and municipal associations. E-invoices are also exempt in cases of procurement outside the EU and where invoice issuers do not have the necessary technical capabilities.

Format: XRechnung or other standards compliant with EN 16931
Platform: Service Portal Baden-Württemberg
Transmission channels: Upload, email, PEPPOL
Invoice content: Bank details, payment terms, email address of the invoice issuer (additional information, if provided during procurement: supplier number, purchase order number)

Bavarian E-Government Act (BayEGovG)

Validity: Entered into force on April 18, 2020, and updated on August 1, 2023
Scope: Bavaria, B2G
Origin: Free State of Bavaria

In Bavaria, public authorities are required to accept and process invoices in electronic form. An exception applies to invoices up to EUR 1,000 net, excluding VAT. However, companies in Bavaria are not obliged to submit electronic invoices to public authorities.

Format: EN 16931-compliant formats, in practice primarily XRechnung
Platform: Central invoice receipt solutions
Transmission channels: Submission via central invoice receipt platforms of public authorities, for example via upload or web form, as well as through the PEPPOL network; email is only permitted to a limited extent
Invoice content: Identification number, payment terms, recipient’s bank details, email address of the invoice issuer

E-Invoicing Ordinance of Bremen

Validity: Entered into force on August 1, 2021
Scope: Bremen, B2G
Origin: Free Hanseatic City of Bremen

In Bremen, contractors are required to issue electronic invoices to public authorities. Public authorities, in turn, are obliged to receive and process electronic invoices. However, this does not apply in cases involving confidential information or for direct awards under the below-threshold procurement regulation.

Format: XRechnung standard
Platform: zERIKA
Transmission channels: Submission via central platforms, for example through the PEPPOL network or via upload and web form
Invoice content: In accordance with EN 16931, in particular information on the invoice issuer, payment, and references

E-Invoicing Ordinance of Berlin

Validity: Entered into force on August 1, 2021
Scope: Berlin, B2G
Origin: Berlin

In Berlin, invoice issuers are not required to issue and transmit their invoices electronically. However, public authorities are obliged to receive and process electronic invoices.

Format: EN 16931-compliant formats such as XRechnung
Platform: OZG-RE
Transmission channels: Submission via central platforms, for example via web form, upload, or through the PEPPOL network
Invoice content: Routing ID (Leitweg-ID), bank details, payment terms, and a De-Mail address or an email address of the invoice issuer (additional information, if provided during procurement: supplier number, purchase order number)

E-Invoicing Ordinance of Brandenburg

Validity: Entered into force on April 1, 2020
Scope: Brandenburg, B2G
Origin: Brandenburg

Contracting authorities are required to ensure the receipt and processing of electronic invoices, provided that the Public Procurement Chamber of the State of Brandenburg is responsible for contracts above the EU threshold. However, this does not apply in cases involving confidential information. Contractors are not necessarily required to issue and submit electronic invoices to public authorities.

Format: XRechnung standard or other standards compliant with EN 16931
Platform: OZG-RE
Transmission channels: Web entry, web upload, email, PEPPOL
Invoice content: Routing ID (Leitweg-ID), bank details, payment terms, email address of the invoice issuer (additional information, if provided during procurement: supplier number, purchase order number, and file reference number, if available)

Hamburg E-Invoicing Act

Validity: Entered into force on January 1, 2022
Scope: Hamburg, B2G
Origin: Free and Hanseatic City of Hamburg

In Hamburg, all contractors of public authorities are required to submit invoices electronically. This generally applies from a net amount of EUR 1,000 for goods and services, and from EUR 3,000 for construction services. Public authorities are obliged to ensure the receipt and processing of electronic invoices. Exceptions apply to certain types of contracts of minor importance, invoices containing confidential information, and cases of undue hardship.

Format: XRechnung standard or other standards compliant with EN 16931
Platform: Hamburg Service – e-invoicing portal
Transmission channels: Email, e-invoicing portal, PEPPOL
Invoice content: Not specified

E-Invoicing Ordinance of Hesse

Validity: Entered into force on April 18, 2020
Scope: Hesse, B2G
Origin: Hesse

In Hesse, public authorities are required to accept and process invoices in electronic form. Exceptions apply to cash and immediate payments, cases of undue hardship, invoices up to EUR 1,000 net excluding VAT, and proceedings of courts and public prosecutors.

The Hessian E-Invoicing Ordinance obliges public authorities to accept electronic invoices but does not impose a general obligation on companies to issue electronic invoices.

Format: XRechnung standard or other standards compliant with EN 16931
Platform: OZG-RE
Transmission channels: Web entry, upload, email, PEPPOL
Invoice content: Identification number, bank details, payment terms, email address (additional information, if provided during procurement: supplier number, purchase order number)

E-Invoicing Ordinance of Mecklenburg-Western Pomerania

Validity: Entered into force on June 29, 2021, with Section 8 effective from April 1, 2023
Scope: Mecklenburg-Western Pomerania, B2G
Origin: Mecklenburg-Western Pomerania

Invoice issuers are required to issue and transmit invoices in an electronic format to invoice recipients, regardless of the contract value. Contracting authorities are obliged to ensure the receipt and processing of electronic invoices. Exceptions apply to invoices containing confidential information.

Format: EN 16931-compliant formats such as XRechnung
Platform: OZG-RE
Transmission channels: Submission via central platforms, for example via web form, upload, or through the PEPPOL network; email is only permitted to a limited extent
Invoice content: Routing ID (Leitweg-ID), bank details, payment terms, email address of the invoice issuer (additional information, if provided during procurement: supplier number, purchase order number)

E-Invoicing Ordinance of Lower Saxony

Validity: Entered into force on April 18, 2020
Scope: Lower Saxony, B2G
Origin: Lower Saxony

In Lower Saxony, invoice issuers are not required to issue and transmit their invoices electronically. However, public authorities are obliged to receive and process electronic invoices. The State of Lower Saxony provides a platform for public authorities, the Central e-Invoicing Receipt System Lower Saxony (ZeRN), through which electronic invoices can be received.

For contracting authorities connected to ZeRN, e-invoices can be submitted via the Lower Saxony Online Application System for Administrative Services (NAVO), by email, or through the PEPPOL network. If a contracting authority is not connected to ZeRN, the transmission channel must be clarified directly with the authority. Regardless of whether ZeRN is used or not, the routing ID (Leitweg-ID) must be obtained from the contracting authority in advance.

Format: XRechnung standard or other standards compliant with EN 16931
Platform: NAVO
Transmission channels: Email, web upload, web entry, PEPPOL
Invoice content: Bank details, payment terms, De-Mail address or email address of the invoice issuer (additional information, if provided during procurement: supplier number, purchase order number, and a routing ID assigned to the invoice recipient by the competent authority)

E-Invoicing Ordinance of North Rhine-Westphalia

Validity: Entered into force on April 1, 2020
Scope: North Rhine-Westphalia, B2G
Origin: North Rhine-Westphalia

In North Rhine-Westphalia, invoice issuers are not required to issue and transmit their invoices electronically. However, public authorities are obliged to receive and process electronic invoices. Exceptions apply to direct awards without a procurement procedure and to invoices containing confidential information.

Format: XRechnung standard or other standards compliant with EN 16931
Platform: NRW
Transmission channels: Web entry, web upload, email, De-Mail, PEPPOL
Invoice content: Identification number, bank details, payment terms, and a De-Mail address or an email address of the invoice issuer (additional information, if provided during procurement: supplier number, purchase order number, and cost allocation)

E-Invoicing Ordinance of Rhineland-Palatinate

Validity: Entered into force on April 18, 2020
Scope: Rhineland-Palatinate, B2G
Origin: Rhineland-Palatinate

In Rhineland-Palatinate, invoice issuers are not required to issue and transmit invoices in electronic form. However, public authorities must be able to receive and process electronic invoices. This does not apply to invoices containing confidential information.

Format: XRechnung standard or other standards compliant with EN 16931
Platform: Central e-invoicing receipt system RLP
Transmission channels: Web upload and web entry via the ZRE RLP as well as PEPPOL
Invoice content: Not specified

E-Invoicing Ordinance of Saarland

Validity: Entered into force on July 31, 2020
Scope: Saarland, B2G
Origin: Saarland

In Saarland, companies are required to submit electronic invoices to public authorities. The same central platform for e-invoicing receipt is used as in Rhineland-Palatinate. Public authorities are also obliged to accept and process invoices in electronic form. Exceptions apply to cash and immediate payments, cases of undue hardship, invoices up to EUR 1,000 net excluding VAT, invoices containing confidential information, and cases where invoice issuers do not have the necessary technical capabilities.

Format: XRechnung standard or other standards compliant with EN 16931
Platform: Central e-invoicing receipt system RLP
Transmission channels: Web upload and web entry via the ZRE as well as PEPPOL
Invoice content: Identification number (routing ID / Leitweg-ID), bank details, payment terms, and email address of the invoice issuer (additional contract-specific information, such as order references, may also be required)

Saxon E-Government Act

Validity: Entered into force on April 18, 2020
Scope: Saxony, B2G
Origin: Saxony

In Saxony, there is no obligation for invoice issuers to create and submit invoices in electronic form. In contrast, public authorities in Saxony are required to receive electronic invoices and provide the necessary processing systems. This does not apply to invoices containing confidential information.

Format: XRechnung standard or other standards compliant with EN 16931
Platform: ZRE or OZG-RE
The applicable invoice receipt platform can be determined based on the underlying contract or directly from the invoice recipient.
Transmission channels: Web entry, web upload, PEPPOL
Invoice content: Identification number (routing ID / Leitweg-ID), bank details, payment terms, and email address of the invoice issuer (additional contract-specific information, such as order references, may also be required)

E-Invoicing Ordinance of Saxony-Anhalt

Validity: Entered into force on April 18, 2020
Scope: Saxony-Anhalt, B2G
Origin: Saxony-Anhalt

In Saxony-Anhalt, invoice issuers are not required to issue and transmit invoices in electronic form. However, public authorities are obliged to be able to receive and process electronic invoices. This does not apply to invoices containing confidential information.

Format: XRechnung standard or other standards compliant with EN 16931
Platform: OZG-RE
Transmission channels: Web entry and web upload via OZG-RE as well as PEPPOL
Invoice content: Routing ID (Leitweg-ID), bank details, payment terms, and a De-Mail address or an email address of the invoice issuer (additional information, if provided during procurement: supplier number)

E-Invoicing Ordinance of Schleswig-Holstein

Validity: Entered into force on April 18, 2020
Scope: Schleswig-Holstein, B2G
Origin: Schleswig-Holstein

In Schleswig-Holstein, there is no mandatory requirement for invoice issuers to create and submit invoices in electronic form. In contrast, public authorities must ensure the receipt and processing of electronic invoices. Invoices containing confidential information are exempt from this requirement.

Format: XRechnung standard or other standards compliant with EN 16931
Platform: OZG-RE
Transmission channels: Web entry, web upload, email, De-Mail, PEPPOL
Invoice content: Routing ID (Leitweg-ID), bank details, payment terms, and a De-Mail address or an email address of the invoice issuer (additional information, if provided during procurement: supplier number)

E-Invoicing Ordinance of Thuringia

Validity: Entered into force on November 27, 2019
Scope: Thuringia, B2G
Origin: Thuringia

In Thuringia, invoice issuers are not required to issue and transmit electronic invoices. In contrast, public authorities are obliged to receive and process e-invoices. This does not apply to invoices containing confidential information.

Format: XRechnung standard or other standards compliant with EN 16931
Platform: OZG-RE
Transmission channels: Web entry and web upload via OZG-RE as well as PEPPOL
Invoice content: Routing ID (Leitweg-ID), bank details, payment terms, and a De-Mail address or an email address of the invoice issuer (additional information, if provided during procurement: supplier number)

Act to Strengthen Growth Opportunities, Investment and Innovation, as well as Tax Simplification and Tax Fairness (Growth Opportunities Act)

Validity: Government draft, expected to enter into force on January 1, 2024
Scope: Nationwide, B2B
Origin: Germany

The Growth Opportunities Act in Germany предусматриes that electronic invoicing between businesses (B2B) will become mandatory in the future. This step must be seen in the context of the EU’s ViDA initiative, which aims to introduce an EU-wide electronic VAT reporting system to replace the current “recapitulative statement” (EC Sales List), thereby significantly reducing cross-border VAT fraud.

From 2025 onwards, a clear distinction is to be made between electronic invoices and other types of invoices. An electronic invoice is defined as an invoice that is created, transmitted, and received in a specific, structured electronic format.

Although transitional arrangements will apply for companies until 2027, all invoices in the B2B sector must be exchanged electronically (and in line with the new legal requirements) from 2028 onwards.