|B2G e-invoicing is mandatory, B2B e-invoicing mandate is expected to go live from 2026||No|
Germany Electronic Invoicing and Digital Reporting Requirements
|Indirect tax control regime||Post audit|
|E-Invoicing/CTC Model||B2G E-Invoicing|
|Obligation status||Live: e-invoicing the Federal government Partially live: E-invoicing in remaining public administration|
|Governing entity||Federal Ministry of Interior and Community (BMI) and the Federal Ministry of Finance (BMF)|
|Infrastructure/platform||The Central Federal Invoice Receipt Platform(ZRE), the platform of the central Federal Administration ;Online Access Law - Compliant Invoice Receipt Platform (OZG - RE) intended for affiliated institutions of the indirect federal administration and cooperating federal states. Each state may have its own platform.|
|Peppol connectivity||Yes, however not fully implemented nationwide|
|Taxpayers||Suppliers to Federal Public Institutions and affiliated indirect federal administrations. Suppliers to public entities in numerous other federal states|
|Domestic Transactions||B2B - no, B2C - no, B2G - yes, on the Federal level, partially within Federal states|
|Cross-border Transactions||Export - no required, Import - not required|
|Documents||Invoices (numerous types), Credit notes|
|Supplier-side requirements (AR)|
|Format(s) while sending to the platform||XRechnung and in some cases ZUGFeRD is also allowed|
|Format for exchange with buyer/recipient||XRechnung and in some cases ZUGFeRD is also allowed|
|Buyer-side requirements (AP)|
|Receiving document in electronic format||Mandatory for all German public entities|
|Validation required||In some cases|
|Acknowledgement of receipt||Required for all German public entities|
|Response to the document received (Accept or reject)||Required for all German public entities|
|Archiving Period||10 years|
|Other Digital Reporting Obligations|
|SAF-T or other accounting filings||No|
The implementation of the E-Invoicing system in Germany for B2G transactions started in 2017. The plan is to finalize the project within 2025 so that the only form of the invoice valid within B2G operations shall be an e-invoice.
From November 27, 2020, the suppliers of Federal Government institutions are obliged to send only e-invoices to public authority buyers. Only the E-Invoices in the meaning of the Federal E-Invoice Ordinance may be sent to the authorities.
The e-invoices should be sent to the State platforms, specifically developed and established for this purpose. These platforms represent the central access points for reporting of e-invoices. There are, at the moment, two main central platforms for reporting of e-invoices:
- The Central Federal Invoice Receipt Platform(ZRE), the platform of central Federal Administration(e.g. ministries and higher federal authorities) and
- Online Access Law - Compliant Invoice Receipt Platform(OZG - RE) where economic operators should submit e-invoices intended to affiliate institutions of the indirect federal administration and cooperating federal states.
According to the Federal E-Invoicing Ordinance, for B2G transactions, the preferred standard which should be used is XRechnung. This doesn’t exclude the possibility of using other formats.
What Types of Businesses Does This Apply to?
It applies to suppliers of federal public institutions and associated indirect federal administrations. It also applies to suppliers to public bodies in many states.
Governmental Body Responsible for E-invoicing in Germany
The Federal Ministry of the Interior and Community (BMI), alongside the Federal Ministry of Finance (BMF), are the two main central public authorities responsible for the development, monitoring, and implementation of e-invoicing on the Federal level.
Specifically designed public authority for coordinating and implementing parts of the e-invoicing project is The Coordination Office for IT Standards (KoSIT) which maintains and develops the German E-Invoicing Standard (XRechnung) on behalf of the IT Planning Council .
KoSIT became the German Peppol authority in June 2018, with the responsibility of maintaining XRechnung. KoSIT's main tasks are to assist the IT Planning Council in adopting IT interoperability and IT security standards, as well as to manage joint federal and state e-government projects.
Penalties for Not Adhering to Germany's E-invoice Mandates
Late issuance of invoices, non-compliance with the rules on the storage of invoices may result in penalties. The penalty may not exceed EUR 5,000 for each offence.
What does the e-invoicing process in Germany look like?
The B2G E-Invoicing flow:
- The user should first make a user account before he can use the invoice receipt platforms ZRE and OZG-RE. (Not required in submission is dont via Peppol) The user accounts of the federal government's invoice receipt platforms enable taxpayers, among other things, to track the status of the electronic invoices that have been submitted.
- The supplier sends the E-Invoice to the platform through the usage of one of the permitted transmission channels, Email, Peppol, Upload or manually, which are given as an option by the Federal government.
- For transfer of invoices in high volume transmission methods such as web service via Peppol, e-mail is suggested
- For small batches and/or single e-invoice transfers, the manual upload via the central platforms is a valid option
After the e-invoice has been reported to the Platform, the Platform checks for completeness and its conformity with the German E-Invoicing standard in syntax and semantics. Once the checks are complete, the invoice is then made available by the platform to the intended receiver indicated by the buyer reference or “Leitweg ID”.
Is SAF-T Needed in Germany?
There are no SAF-T obligations in Germany.
E-Invoicing & Global Tax Automation with Fonoa
One way to comply with Digital Reporting Requirements in Germany is to use a provider like Fonoa.
With Fonoa you can:
- Have one integration for your global needs, including Germany
- Save time and money by automatically cleaning your data to minimize errors and manual work
- Utilize our validation mechanisms to ensure reporting accuracy, data completeness, full control, and compliance
- Rest assured that transactions are successfully reported or queued for internal investigation with our retry mechanisms
- Get full visibility with our dashboards by filtering criteria, analyzing granular transaction data, and quickly importing /exporting information