Webinar E-Invoicing mandates (Poland and Germany): Continuing the Conversation

Our recent webinar, "E-Invoicing mandates on the examples of Germany and Poland: Key Considerations, Opportunities, and Challenges" took place on June 26, 2024. We received many excellent questions from the audience, but our speakers, Michał Kacperek and Rafał Trojanowski, couldn't address all of them during the live session. Therefore, we're continuing the conversation by answering those questions below.

If you missed the webinar, there's still time! You can watch it on-demand here. If you have further questions that aren't answered below, don't hesitate to contact our experts.

Are credit notes (credit note procedure) to be treated in the same way as invoices?

Yes. Please note that from the technical point of view a credit notes are invoices, however in Poland a new invoice type (correction invoice) is the only way to correct an invoice.

Do you know anything about Hungarian regulations in this matter, when it will be mandatory and for what kind of model they are going for? And also same question about Czechia.

In case of Hungary there is already a similar system – NAV 3.0. This system however – contrary to the ‘Clearing’ as known from a.o. Poland, Italy, Romania or Serbia – deploys the so called ‘Real Time Invoice Reporting’ model. Despite the difference of ‘invoice clearing’ to ‘invoice reporting’ both systems are ‘Centralized Systems’. Electronic invoice transmission is currently not mandatory in Hungary and in Czechia.

Germany: Are companies required to accept all formats/ any format: ZUGFeRD, xRechnung, invoice via PEPPOL?

The law does not impose a mandatory PEPPOL transmission, however it is one of channels that could be used. Despite not being mandatory, it can be expected, that more taxpayers will use Peppol for B2B invoice exchange purposes of this channel, as it meets the German requirements and allows the exchange of CEN compliant invoices. 

Is there already a technical guidelines for this from the government?

Polish specification will be updated but is already available since 2022. Germany does not issues technical specifications, as there will be no central platform, however format specifications (ZUGFeRD, xRechnung) are available. 

How businesses are required to receive e-invoices not required to send e-invoices in Germany. Isn't that logical to implement both at the same time?

This is the usual approach that the given country implements both outgoing and incoming invoices (e.g. Poland, Italy, Serbia, Romania). The German law mandates both sending and receiving of e-Invoices, however due to the many exceptions during the interim period, the obligation is often referred to as a “de facto” receiving mandate. So in theory only obligation ‘to be able to receive and process’ but in real life also ‘to be able to send’.

We were told that as a law, we have to comply with the channel the customer wants to receive, especially for B2G transactions. So if the public sector customer wants to receive xRechnung via email, we have to by law be able to send the via email only. Is this true? 

B2G invoices are governed by public procurement legislation on e-Invoicing, which indeed imposes (in some cases) a mandate to issue electronic invoices and – if applicable – through a certain channel. This does not apply to some federal states. The new reform covers B2B transactions as well, which does not mean that the B2G obligation will cease to exist.

Are credit notes or returns also be part of "e-invoicing" in Germany?

Yes. As answered in another question credit notes are technically invoices. Each document type which is considered to be an invoice in the understanding of the VAT act is subject to the mandate. 

I would appreciate clarification regarding the e-invoice process in Germany, specifically concerning the PEPPOL network. Is it mandatory for businesses to utilize the PEPPOL network for e-invoicing? Additionally, could you explain the procedure for recipients to retrieve incoming invoices when they are sent via the PEPPOL network?

No. You are not obliged to use PEPPOL, as this is only one of many possible transmission channels. This however is an option that is more recommendable than an e-mail due to security reasons.

In case of retrieval of invoices that came via PEPPOL it can be more complicated as you might receive XRechnung/XML that might require conversion into your native format of the IT System you use (e.g. and Idoc in case of SAP) or a human readable format e.g. a PDF created out of XRechnung.

Germany e-Invoicing: if a company has a system that supports Zugferd, but does not accept other formats - i.e. Xrechnung, - is this sufficient readiness for the requirements from 1.2025?

No, in general all formats compliant with the CEN Norm should be accepted. 

Even though we are sending customers xRechnung they still demand for pdfs for reference purpose. Could this lead to double invoicing problem for us?

In such a case it is recommended to use ZUGFeRD as it is a PDF with an embedded XML. If the given customer still insists on XRechnung it can be visualized as a PDF and sent together.

About the Authors

Michał Kacperek
Senior Requirements Engineer at Comarch
(LL.M. Bucerius Law School)

Michał works with Comarch from the beginning of 2020 advising companies from the DACH and BeNeLux region within digitization of documents and processes in their organizations. He is responsible for topics related to electronic data interchange e.g. e-invoicing, accounts payable automation, enterprise content management and the related e-invoicing or e-reporting obligations.

Rafał Trojanowski
Head of Legal Compliance at Comarch

Rafał is an analyst and Head of the Legal Compliance team in the Comarch e-invoicing/EDI Business Unit. He specializes in carrying out data exchange and document management projects in countries where legal policies concerning e-invoicing were introduced.

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