Germany’s B2G e‑invoicing supplier mandates: state‑by‑state rollout

1. When was the B2G e‑invoicing mandate first introduced?

The obligation for German public bodies to receive electronic invoices is rooted in EU Directive 2014/55/EUopen_in_new, the federal e‑invoicing ordinance E‑Rechnungsverordnung – ERechVopen_in_new and various state‑level laws (E‑GovG, E‑Rech‑VO and equivalents). Together, these rules mean that from April 2020, all public contracting entities at both state and federal level must be able to receive e‑invoices.​

However, the timeline for when suppliers are actually required to issue e‑invoices to these authorities has been much less harmonised, with mandates emerging at different times and with slightly different designs across the Bundesländer.​

2. States and authorities with active supplier mandates

At present, several public sector segments already require or allow suppliers to send only e‑invoices, typically in the XRechnung format and often via Peppol. The following authorities have supplier e‑invoicing mandates or mandate options in place:​

• Federal authorities – both central and sub‑central bodies are Peppol‑connected and have supplier e‑invoicing obligations.​
• State authorities in Bremen – Peppol‑connected, with e‑invoicing mandated for suppliers.​
• North Rhine‑Westphalia – contracting authorities may require their suppliers to issue e‑invoices; Peppol connectivity is available.​
• Lower Saxony – public authorities can, since 1 July 2021, contractually agree on supplier e‑invoicing obligations; Peppol connection was expected from spring 2022.​

In these jurisdictions, contracting authorities may reject invoices issued on paper or as non‑CEN‑compliant PDF files, effectively pushing suppliers towards compliant electronic formats.​

3. Timelines for additional federal states

A further group of states has set clear dates for when their public authorities will start requiring electronic invoices from suppliers:​

• Baden‑Württemberg – From 1 January 2022, suppliers to state authorities must submit invoices electronically to the central state invoicing office; see official info: Baden‑Württemberg – central invoice receiptopen_in_new.​
• Hamburg – From 1 January 2022, contracting parties supplying public institutions and authorities must send e‑invoices; details here: Hamburg – e‑invoiceopen_in_new.​
• Saarland – From 1 January 2022, all invoices to public clients must be electronic; information is provided via the portal: Saarland – e‑invoice portalopen_in_new.​
• Mecklenburg‑Western Pomerania – From 1 April 2023, suppliers are required to send e‑invoices; legal basis: E‑RechV MVopen_in_new.​
• Rhineland‑Palatinate – From January 2024, all invoices to public clients must be e‑invoices; more details at: Rhineland‑Palatinate – e‑invoiceopen_in_new.​
• Hesse – From 18 April 2024, suppliers performing public contracts must send e‑invoices to state authorities; see: Hessen – electronic invoicesopen_in_new.​

Most of these states either already have Peppol connectivity or plan to connect, enabling automated machine‑to‑machine delivery of XRechnung‑compliant invoices.​

4. Overall rollout status and what comes next

Taking the federal level and all states together, 10 out of 17 government “fragments” (16 Bundesländer plus the Federal Government) have now directly or indirectly implemented supplier e‑invoicing mandates. In practice, this means that in these areas, invoices must be submitted in XRechnung format via email, portal upload or the Peppol network, rather than on paper or in simple PDF.​

The remaining seven states – Bavaria, Berlin, Brandenburg, Saxony, Saxony‑Anhalt, Schleswig‑Holstein and Thuringia – have not yet fully mandated suppliers but are widely expected to follow, making the question when, not if, a nationwide B2G supplier obligation will be in place. Some administrations, such as Rhineland‑Palatinateopen_in_new, have already started issuing vendor information letters to prepare their suppliers for the transition.​

For suppliers, this fragmented but accelerating rollout means that a scalable solution capable of generating XRechnung and connecting to multiple channels (portals, email, Peppol) across all German public bodies is increasingly essential.