In Germany, e-invoices have been mandatory for certain companies and clients for several years. Whether the obligation applies depends on whether you issue invoices to public clients (federal, state, or municipal authorities) or private business clients. The key deadlines are:
Federal administration: mandatory for invoices to authorities since November 27, 2020
States and municipalities: phased in, some already since 2021, others starting in 2025
Private companies: no general obligation, but legal advantages exist for structured electronic invoices (ZUGFeRD/XRechnung possible)
Who is affected?
1. Public clients (B2G)
The B2G e-invoicing requirement (Business-to-Government) applies to all invoices sent to public institutions:
Federal ministries, federal agencies, and subordinate authorities
State and municipal authorities, depending on the state and introduction date
Recipients of public funding if the invoice is part of a public subsidy
Note: The obligation applies even for small amounts starting from €1, as long as it is an invoice to a public client.
2. Private companies (B2B)
For B2B, there is currently no legal obligation to use e-invoices. Companies can voluntarily issue e-invoices, e.g., in ZUGFeRD or XRechnung format, to simplify invoicing and promote digitalization.
EU directive and German implementation
EU Directive 2014/55/EU: Requires public clients to be able to receive electronic invoices in a standardized format
E-Invoicing Act & ERechV (Germany): Implement the EU requirements, mandatory from November 27, 2020, at the federal level
XRechnung 3.0: Current national standard format since February 1, 2025, for invoices sent via Peppol to public clients
All public clients must accept invoices electronically in the standardized format.
Deadlines at a glance
Client | Deadline / Requirement | Format & Notes |
Federal authorities (Bund) | from 27.11.2020 | XRechnung; Peppol recommended |
States & municipalities | phased, partly from 2021, partly until 2025 | XRechnung or ZUGFeRD 2.1.1 in “XRechnung” profile |
Private companies (B2B) | voluntary | ZUGFeRD or XRechnung possible, not mandatory |
Note: From February 1, 2025, XRechnung 3.0 National Ruleset applies for invoices sent via Peppol in Germany. Older versions will no longer be accepted.
Consequences of non-compliance
Invoice rejection: PDF invoices or non-compliant XML files will not be accepted by authorities
Delayed payments: No valid e-invoice means no payment
Contractual penalties: Depending on the client, additional deadlines or fines may apply
Summary
E-invoices are mandatory for invoices to public clients in Germany (federal, state, municipal)
Deadlines vary: federal authorities since 2020, states/municipalities phased in until 2025
Private companies: voluntary, but recommended for more efficient digital processes
Format: XRechnung 3.0 is standard for public clients; ZUGFeRD 2.1.1 optional for B2B
💡 Tip: Use tools like Accountable to make sure your e-invoices include all required fields, are correctly validated, and reach recipients on time.