Germany Joins the e-Invoicing Revolution

Germany Joins the e-Invoicing Revolution

Introduced regulations oblige suppliers to send e-invoices to German public administration entities (on the federal level). So, it doesn't matter if you're from France, Belgium, Italy, the Netherlands, or anywhere else - if you're one of the suppliers, you need to go by the new rules. 

Also, forget about sharing PDFs. From now on, you have to send structured invoices, that is files created in the right document format such as XRechnung.

Scroll through this space to learn how to achieve full legal compliance with minimal effort and at a low cost.

Who have been affected by this change?

If you are a supplier for German public administration institutions, you are obliged to send them structured e-invoices.

XRechnung - THE e-Invoicing Format in Germany

XRechnung is an XML-based invoice format preferred by German authorities, fulfilling the criteria of the European core calculation and being the response to the CEN standard (CEN/TC 434). Other formats, such as ZUGFeRD 2.0 or Factur-X, remain applicable for B2B transactions, but all suppliers for the German public administration are obliged to switch to X-Rechnung.

An XRechnung file can be sent via one of the many transmission channels, such as the German ZRE, OZG RE, VPX platforms, as well as the European PEPPOL network.

What is the PEPPOL network?

OpenPEPPOL is a non-profit organization that provides a vast network of electronic document exchange services, used mainly for e-invoicing purposes (for both B2G and B2B transactions).

It is not a separate platform, but a virtual infrastructure that binds other e-invoicing platforms together, no matter if they are governmental or third-party solutions. The German OZG-RE (Online Access Act compliant e-invoice platform), for example, also features a PEPPOL interface.

PEPPOL network
Need help with becoming compliant with the new regulations?

The Future: What should we expect?

The new e-invoicing laws apply only to B2G operations for now, but we should expect German authorities to extend the regulations to cover B2B transactions sometime soon. For the time being, B2B e-invoicing remains optional. 

Our solution? Actually, there are two...

To help companies send e-invoices to public administration, we provide two platforms: Comarch e-Invoicing Cloud and Comarch e-Invoicing

Comarch e-Invoicing

Comarch e-Invoicing is a comprehensive, SaaS solution created mainly for large enterprises. Helping you carry out the most complex B2B & B2G document exchange operations, it guarantees both higher quality of data and lower operational costs.

Comarch e-Invoicing Cloud

Comarch e-Invoicing Cloud is an easy-to-use, affordable tool designed for small and mid-size companies. Providing instant access to a virtual environment that is easy to navigate, it enables you to transfer e-invoices to both public institutions and private companies in no time - no matter where you are.  

Guaranteed compliance with:

Legal regulation changes in Germany

Characteristics of the e-invoicing in Germany

Mandatory/not mandatory

  • Since November 27th 2020, e-invoicing has been mandatory on federal level and in the federal state of Bremen.
  • As of January 1st 2022, B2G e-invoicing will become mandatory in the federal states of Saarland and Baden Württemberg.
  • In terms of the B2B area, the German government intends to introduce mandatory e-invoicing as soon as possible in order to combat VAT fraud.

E-invoice format and platform

  • The XRechnung format is required for B2G invoices. It is a semantic data model based on XML. It complies with the European standard EN 16931.
  • Platform for sending e-invoices directly to the German federal administration: ZRE (the Zentrale Rechnungseingangsplattform).
  • Platform for sending e-invoices indirectly to the German federal administration: OZG-RE (the Onlinezugangsgesetz-konforme Rechnungseingangsplattform).

E-invoicing process description

The German B2G e-invoicing system is decentralized. The access points for the reception of B2G e-invoices from suppliers at the federal level are the platforms ZRE and OZG RE. At state level, each state could opt to use the central government’s platform or other systems (or none).

Integrity and authenticity

Qualified Electronic Signature is one of the accepted methods. Data sealed with a qualified electronic seal enjoy the presumption of integrity and authenticity.


Storage period: 10 + 3 years

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