E-invoicing in Germany: Timeline, XRechnung, Peppol and B2B Mandate Roadmap

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E‑invoicing in Germany: timeline, XRechnung, Peppol and B2B mandate roadmap

Germany has been building its e‑invoicing framework for more than a decade, moving from simple electronic PDFs to structured, standardised formats such as XRechnung and Peppol BIS. Today, public sector e‑invoicing is largely mandatory, and a phased B2B e‑invoicing obligation is on the way.​

1. How Germany’s e‑invoicing journey started

Germany’s modern e‑invoicing framework began with the implementation of Directive 2010/45/EUopen_in_new, which required EU Member States to treat electronic invoices the same as paper invoices. Germany transposed this into national law through the Tax Simplification Act 2011open_in_new and amendments to Section 14 UStGopen_in_new, granting e‑invoices full legal equivalence to paper invoices.​

A second key milestone was Directive 2014/55/EUopen_in_new, which narrowed the EU definition of an e‑invoice and excluded purely human‑readable formats such as PDF, TIFF or JPEG from being considered valid e‑invoices. To implement this, Germany introduced Section 4aopen_in_new into the eGovernment Act (EGovG)open_in_new, enabling the federal government to regulate the design of e‑invoices by ordinance.​

The Federal Ministry of the Interior then issued the e‑bill ordinance (ERechV)open_in_new, which requires federal authorities to receive and process e‑invoices in XRechnungopen_in_new or other formats compliant with the European standard on e‑invoicingopen_in_new from 27 November 2018. One year later, this requirement extended to all other federal contracting authorities, such as tax offices, police authorities, universities and hospitals.​

In October 2018, the IT Planning Councilopen_in_new decided that all authorities at federal and state level must offer Peppolopen_in_new where automated data exchange is used for delivering e‑invoices, paving the way for consistent use of the Peppol eDelivery network.​

2. XRechnung and Peppol in Germany

XRechnung is Germany’s core B2G e‑invoicing standard and plays a central role in achieving EU‑wide interoperability. KoSITopen_in_new published XRechnung version 1.0 in October 2017, and the standard is referenced in ERechVopen_in_new, which generally requires invoice issuers to use the XRechnung data exchange format when sending e‑invoices to public entities.​

In April 2018, the IT Planning Council mandated the use of the Peppol eDelivery network for e‑invoice transmission and established KoSIT as the German Peppol Authorityopen_in_new. In cooperation with OpenPeppolopen_in_new, Germany introduced Peppol BIS 3 (DE CIUS) as a country‑specific usage specification, enabling e‑invoice exchange in both Peppol BIS and XRechnung formats over the Peppol infrastructure.​

Because XRechnung is a German‑specific implementation, businesses are advised to work with Peppol Service Providers that can create, send and receive XRechnung and that are accredited under the German Peppol Authority’s national requirementsopen_in_new, set out in Annex 5open_in_new.​

3. Leitweg ID, routing and public portals

To route e‑invoices to the correct public authority, Germany uses a unified routing identifier known as the Leitweg ID. This routing ID is a mandatory field in the XRechnung schema and contains components such as state code, fine addressing and a check digit (with some administrative codes being optional), allowing platforms to distribute invoices correctly.​

Peppol routing IDs

For Peppol transmissions, the following routing identifiers are used:​

• DE: LID (9958: Leitweg ID) – recently deprecated
• DE: LWID (0204: Leitweg ID)
• DE: VAT (9930: German VAT number)

B2G e‑invoicing portals

Germany uses both central and decentralised portals to receive e‑invoices from suppliers:​

• Federal Central Invoice Receiving Platform (ZRE) – mandatory gateway for federal administration, receiving XRechnung invoices.​
• Online access law‑compliant platform OZG‑RE – invoice receipt platform for indirect federal administration and several states.​

Additional state‑level portals include, for example:​

• Bremen – zERIKAopen_in_new
• Hamburg – Elektronische Poststelleopen_in_new
• North Rhine‑Westphalia – Vergabe E‑Rechnungsportalopen_in_new
• Rhineland‑Palatinate – E‑Rechnungseingang RLPopen_in_new
• Saarland – shares E‑Rechnungseingang RLPopen_in_new
• Schleswig‑Holstein – E‑Rechnungsportalopen_in_new
• Baden‑Württemberg – Zentraler Rechnungseingangopen_in_new
• Lower Saxony – NAVOopen_in_new
• Saxony‑Anhalt – E‑Rechnungsportalopen_in_new

Some states rely on OZG‑RE, others operate their own solutions, and a few have not yet clearly communicated their setup. Because there is no public directory mapping each public entity to a specific portal, suppliers often need to confirm the correct portal with their buyer, or rely on Peppol ID routing to identify the registered access point.​

Core portal functionalities

German B2G e‑invoicing portals typically support five core functions:​

1. Authentication – supplier registration and login via user accounts.
2. Invoice creation and submission – manual web forms or upload of in‑house generated XRechnung files.
3. Transmission channels – XML via email, De‑Mailopen_in_new, web upload and Peppol (XRechnung), with Peppol as the only fully automated, machine‑to‑machine channel.​
4. Validation – automatic schema and business rule checks, with non‑compliant invoices rejected; correct placement of the buyer reference/Leitweg ID is critical.​
5. Addressing and forwarding – routing of validated invoices to the correct authority using Leitweg ID or Peppol ID.​

4. Timelines and obligations for public bodies and suppliers

Public contracting authorities (B2G receiving)

Key implementation dates for receiving e‑invoices in XRechnung format are:​

• 27 November 2018 – highest federal authorities and constitutional bodies of the federal government.
• 27 November 2019 – all federal ministries and other federal contracting authorities (tax offices, police, universities, hospitals, etc.).
• 18 April 2020 – federal states and municipalities.​

Suppliers to public authorities (B2G issuing)

Suppliers face a different set of deadlines and state‑level rules:​

• From 27 November 2020 – suppliers to federal authorities and Bremen must issue e‑invoices in XRechnung or another EN‑compliant format; non‑compliant paper/PDF invoices may be rejected.​

Further state‑specific obligations include:​

• Baden‑Württemberg – e‑invoices mandatory from 1 January 2022 to the Central Invoicing Officeopen_in_new.
• Hamburg – e‑invoices required from 1 January 2022 for state authorities, with Peppol as the preferred channel.​
• Saarland – all invoices to public clients must be e‑invoices from 1 January 2022.​
• Mecklenburg‑Western Pomerania – supplier e‑invoicing obligation planned from 1 April 2023, see FeRD 2020open_in_new.​
• Rhineland‑Palatinate – all invoices to public clients must be e‑invoices by January 2024.​
• Hesse – suppliers in public procurement must send e‑invoices to state authorities from 18 April 2024.​

Implementation remains heterogeneous across the 16 Länder, with variations in minimum thresholds, accepted formats (XRechnung, ZUGFeRD 2.0, etc.) and supported channels.​

5. Current status and upcoming B2B e‑invoicing mandate

As of April 2020, the federal infrastructure (ZRE) is live and OZG‑RE is operational for Berlin, Brandenburg, Saxony, Thuringia and Mecklenburg‑Western Pomerania, while multiple other states run their own portals. Some states have still not finalised or publicly communicated their long‑term portal strategy, even though they are required to support e‑invoicing.​

From a model perspective, Germany currently follows:​

• B2G: Centralised/Peppol model with multiple platforms and Peppol connectivity.
• B2B: Post‑audit model, moving towards mandatory EN 16931‑compliant e‑invoices.

Formats and requirements:​

• B2G formats: XRechnung, Peppol BIS, ZUGFeRD.
• B2B formats: EN‑compliant e‑invoices.
• Mandatory issuing: Suppliers to all federal and Bremen contracting authorities; B2B issuing becomes mandatory from 1 January 2027 for taxpayers with turnover above 800,000 EUR and from 1 January 2028 for all taxpayers.​
• Mandatory receiving: All contracting authorities for B2G; all taxpayers must be able to receive EN 16931‑compliant B2B e‑invoices from 1 January 2025.​

Other compliance points:​

• e‑Signature: Not generally required for e‑invoices.
• Archiving period: Currently 10 years; planned reduction to 8 years from 1 January 2025, with certain exceptions.​
• Archiving abroad: Allowed under conditions.

For suppliers, this landscape means managing multiple portals, country‑specific rules and evolving B2B requirements, making it essential to rely on solutions that support XRechnung, Peppol connectivity and state‑level specifics from a single platform.