The e-invoicing community still has fresh memories of the changes introduced in several European countries on the wave of the EU e-invoicing directive.

Germany did not only introduce some basic key points with regard to the implementation of EU law, it also went beyond the provisions of Directive 2014/55 EU.

Who will be obliged to issue e-invoices?

From 27th November, 2020, suppliers acting as contractors for the federal government and its authorities will be obliged to issue invoices in electronic format. Excluded from this obligation are among others direct orders up to a value of €1,000, but the implications of the new law are nevertheless wide-ranging.

How are electronic invoices defined?

In order to be compliant with the new regulations, invoices should be sent in a format which meets the requirements of the European standard for electronic invoicing (EN-16931). In Germany, the preferred format is the XRechnung Standard.

It is crucial to include not only the elements mandatory under tax law, but also those introduced by the regulation on electronic invoices (e-Rechnungsverordnung), as for example the LeitwegID, which is a new identification number of public entities, used to „guide“ the document to the final recipient.

What does it mean for businesses in Germany?

The German e-invoicing regulations are certainly among most complex in the world. This is because competences in the area of e-invoicing are divided between the Federal Ministry of the Interior and all 16 federal states (Länder). Each federal state implemented Directive 2014/55 EU independently, which means that there is a different legal framework in each of them.

In other words, the structure of the German state means that it is not easy to keep track of all changes in this regard. Not all of the federal states have yet decided to make B2G e-invoicing mandatory. The majority of those who have chosen to do so, have also decided not to rush into things, and will introduce the obligation over the next few years.

What is the territorial scope of German e-invoicing regulations?

Bremen is the only federal state to have chosen the same date as on federal level for the introduction of obligatory e-invoicing. It also chose to build its own e-invoicing platform, called ZERIKA.

On the federal level, there are two platforms for federal public administration entities:

  • Zentrale Rechnungseingangsplattform des Bundes (ZRE) – for the direct federal administration
  • OZG-konforme Rechnungseingangsplattform (OZG RE) – for the indirect federal administration



The ZRE Platform (Zentraler Rechnungseingang) was launched in November 2018, and the OZG RE OZG-konforme Rechnungseingangsplattform has been operational since November 2019.

All three platforms (OZG RE, ZRE, ZERIKA) support the use of PEPPOL infrastructure.

Some federal states chose to use the  OZG RE platform created by the federal government, even though they have not yet made electronic invoices mandatory.

Comarch has been constantly developing, implementing and testing new solutions connected to the upcoming deadline, and is ready to assist your business during Germany's invoice digitization process. If you would like to know more, feel free to contact us.


Learn more about Comarch e-Invoicing

Tell us your business needs, and we’ll find the perfect product