On November 27, 2018, the German e-Incoicing Act (2014/55/EU) came into force. The act states that from 27 November 2020, public sector customers, i.e. municipalities and public authorities, are obliged to switch to e-invoice processing. This affects the receipt, processing and dispatch of electronic invoices.
What was planned as a simplification, however, only complicates the situation: Each federal state has its own rules and regulations, some react faster, some slower. What was intended to save 60-80 percent of costs now only raises questions. Which invoice format? What happens when suppliers accept orders from different states? The technical and legal differences present the federal states with a great deal of chaos.
In any case, make yourself and your local authority aware that PDF is not an e-invoice format and is therefore invalid. The legal regulation defines XRechnung as well as formats that are compatible with the CEN standard as permissible.
In order to meet all legal requirements in time for the deadline, you should also carry out an analysis of your IT structure as early as possible.
Law at federal level
Since November 2019, the e-invoicing law has been in force for all federal authorities, whereby invoices from €1,000 upwards can be transferred to the federal government via e-invoicing. From November 27, 2020, all suppliers who issue invoices to the federal government must submit them in certain formats, as so-called XRechnungen.
Baden-Württemberg
New e-Invoicing Regulation in Baden-Württemberg 2022
Exemptions from the obligation to issue invoices electronically:
The law for the promotion of electronic administration of the federal state has already been in force there since January 1, 2016. A corresponding e-invoice regulation is not yet available, however.
Platform: The service portal service-bw.de is to be used to provide a service for the central invoice receipt
Possibilities for transmission: via Web-Upload, via E-Mail, via PEPPOL (possible from 14.03.2022 on)
Permitted formats: XRechnung only
Type of recipient identification: not specified
Limits: Upper and lower limits (public client of the federal state,
sectoral clients and concessionaires); above-threshold (clients of
municipalities and the municipal associations)
Obligation to issue an invoice to the supplier: From 1 January 2022
(exceptions)
Start date: April 18, 2020
Bayern
For the time being, Bavaria is using a decentralized solution for electronic invoices.
Platform: /
Transmission options: email, Peppol, De-Mail
Permissible formats: XRechnung, ZUGFeRD 2.1, all CEN-compliant formats
Type of recipient identification: no routing ID required
Limit values: in the subliminal range only from 21.12.2024
Duty to issue invoices
Brandenburg
The federal state has opted for its own platform solution, the
“Online access law-compliant invoice receipt platform”(OZG-RE).
Platform: OZG-RE
Possibilities for transmission: Portal, Peppol, email
Permissible formats: XRechnung, ZUGFeRD 2.1, all CEN-compliant formats
Type of recipient identification: Routing ID/Peppol ID
Limit values: not specified
Obligation to issue an invoice to the supplier: no
Start date: April 1, 2020
Berlin
In 2019, Berlin has passed its own e-invoicing law, and in the meantime even
a separate regulation for it has been passed.
Platform: OZG-RE
Transmission options: Web service, Peppol, email, De-Mail, file upload
Permissible formats: XRechnung, ZUGFeRD 2.1, all CEN-compliant formats
Type of recipient identification: Routing ID/Peppol ID
Limit values: Obligation to accept and process in the subliminal range
does not take effect until 31.12.2024
Obligation to issue an invoice to the supplier: no
Start date: April 16, 2020
Bremen
Bremen is regarded as one of the pioneers with regard to e-invoicing, as it is already possible to submit electronic invoices in any CEN-compliant format.
Platform: ZERICA
Transmission options: Web service via Peppol, email, De-Mail,
Web registration
Permissible formats: XRechnung, ZUGFeRD 2.1, all CEN-compliant formats
Type of recipient identification: Routing ID/Peppol ID
Limit values: not specified
Invoicing obligation with the supplier: from 27.11.2020
Start date: already active
Hamburg
New e-Invoicing Regulation in Hamburg 2022
In Hamburg, a new regulation for the B2G sector has been in place since 2022. From now on, entrepreneurs are obliged to transmit electronic invoices after the corresponding public contracts or orders have been executed.
In Hamburg, similar to Bremen, electronic invoicing to the administration is already anchored in day-to-day business. However, there is neither an e-invoicing law nor a regulation.
Platform: Central invoice receipt of the Hamburg cash register
Possibilities for transmission: Web service via Peppol, email
Permissible formats: XRechnung, ZUGFeRD 2.1, other e-bill formats
Type of recipient identification: Routing ID/Peppol ID
Limit values: upper and lower threshold
Invoicing obligation with the supplier: not planned
Start date: already active
Hessen
In Hessen, there are currently no plans for a central invoice receipt, but this could possibly be an option in the future.
Platform: no central solution in planning
Possibilities for transmission: first email, later possibly web service via Peppol
Permissible formats: XRechnung, ZUGFeRD 2.1, other
e-invoicing formats
Type of recipient identification: Routing ID with
fine addressing by the Hessian Ministry of Finance
Limit values: upper threshold
Obligation to issue an invoice to the supplier: no
Start date: April 18, 2020
Mecklenburg-Vorpommern
Since 2016, Mecklenburg-Vorpommern has its own e-government law. Concrete guidelines for electronic invoicing are not included.
Platform: Central platform planned
Possibilities for transmission: in planning
Permissible formats: without specification
Type of recipient identification: not specified
Limit values: upper and lower threshold values
Obligation to issue an invoice to the supplier: not specified
Start date: April 18, 2020
Niedersachsen
Although the e-invoicing law should already have been passed in Niedersachsen, it hasn’t been yet. In the draft law there is an obligation on the contracting authorities for electronic invoice receipt from 27.11.2019.
Platform: Centralized invoice receipt via own national portal planned
Possibilities for transmission: first web capture and email, later also Peppol
Permissible formats: all CEN-compliant formats
Type of recipient identification: Routing ID
Limit values: upper and lower threshold values from 18.04.2020 for all authorities of the federal state
Obligation to issue an invoice to the supplier: intended for new allocations
Start date: originally 27.11.2019
Nordrhein-Westfalen
Since mid-2018, a separate e-government law has been in place, including its own e-invoice regulation, which has already been adopted. The special feature in NRW is that the obligation of suppliers to use electronic invoicing is left to the discretion of each contracting authority.
Platform: Awarding Portal of the State of NRW
Possibilities for transmission: Web acquisition, email, De-Mail, file upload,
web service
Permitted formats: XRechnung only
Type of recipient identification: not specified
Limit values: independent of the order value
Obligation to issue an invoice to the supplier: The customer is free to make a decision on the obligation of the supplier
Start date: April 1, 2020
Rheinland-Pfalz
The corresponding federal state law to implement the EU directive
has been approved in Rheinland-Pfalz, but not yet adopted.
Platform: Conception of a state-owned ZRW based on the
architectural concept planned by the federal government and Bremen
Possibilities for transmission: Peppol, email, file upload
Permissible formats: without specification
Type of recipient identification: not specified
Limit values: not specified
Obligation to issue an invoice to the supplier: not specified
Start date: April 2020
Saarland
New e-Invoicing Regulation in Hamburg 2022
In Saarland, the B2G sector has been required to issue electronic invoices since January 1, 2022.
Exempt from this regulation are:
However, invoice recipients can still choose the electronic invoice format on a voluntary basis, after consultation with the invoice issuer.
Saarland has its own IT innovation center and relies on the solution from Rheinland-Pfalz for centralized invoice receipt. Although a separate e-invoicing law has been passed, the corresponding regulation has not yet been issued.
Platform: Cooperation with Rheinland-Pfalz for joint use of the
planned state portal
Possibilities for transmission: Peppol, email, file upload
Permissible formats: not specified
Type of recipient identification: not specified
Limit values: The obligation to receive and
process applies regardless of the exceeding of the
defined threshold values
Obligation to issue an invoice to the supplier: not specified
Start date: April 18, 2020
Sachsen
In Sachsen it is planned to connect all Saxon authorities to the ZRE. For this purpose, the Saxon routine component (ZRL) will be interposed to pick up electronic invoices from the ZRE and forward them to invoice recipients in Sachsen.
Platform: not specified
Possibilities for transmission: not specified
Permissible formats: not specified
Type of recipient identification: not specified
Limit values: not specified
Obligation to issue an invoice to the supplier: no
Start date: April 18, 2020
Sachsen-Anhalt
Sachsen-Anhalt has had an e-government law since 2019. However, this law includes no specifications for electronic invoice receipt by the management. An e-invoicing law for this purpose followed at the end of 2019.
The corresponding e-invoicing regulation is still being planned.
Platform: not specified
Possibilities for transmission: not specified
Permissible formats: not specified
Type of recipient identification: not specified
Limit values: not specified
Obligation to issue an invoice to the supplier: no
Start date: April 18, 2020
Schleswig-Holstein
Already today in Schleswig-Holstein electronic invoices are sent to various recipients from public administration. Since November 27, 2019 also in the intended format XRechnung.
Platform: Central invoice receipt via De-Mail
Transmission options: at least De-Mail, but depending on the recipient also email, web service and Peppol
Permissible formats: XRechnung, ZUGFeRD 2.1 and all CEN-compliant formats
Type of recipient identification: own route ID, now one Peppol ID for all municipalities planned
Limit values: State authorities upper and lower level, other authorities and municipalities only above-threshold
Obligation to issue an invoice to the supplier: no
Start date: April 18, 2020 also for municipalities
Thüringen
Already since November 27, 2019 electronic invoices can be sent to the administration in Thüringen, also in XRechnung format.
Platform: OZG-RE
Possibilities for transmission: Web acquisition, email, De-Mail, file upload, service (Peppol)
Permissible formats: XRechnung
Type of recipient identification: Routing ID, Peppol ID
Limit values: Upper and lower threshold
Obligation to issue an invoice to the supplier: no
Start date: November 27, 2019
XRechnung is mostly used in exchange with authorities and local authorities, i.e. public administrations. The European Union requirement to introduce XRechnung as a standard is intended to create a basis for guaranteeing electronic data exchange in the public sector.
With Directive 2014/55/EU, Germany has started to introduce XRechnung as a standard norm and has committed itself to the EU norm. This standard is thus uniformly regulated for the federal, state and local governments. XRechnung is the standard of the future, as it is available to companies free of charge and is constantly safeguarded by clear and defined controls.
More or less. Here, the invoice issuer can also use a different invoice format, the so-called ZUGFeRD 2.1 format. However, this is only valid if the individual federal states allow this in their invoice regulations and if it is technically necessary. Invoices generated with ZUGFeRD 2.1 must also comply with the EU standard. ZUGFeRD 2.1 and the XRechnung generally meet the same standards. However, XRechnung is mainly considered the standard format by public administrations.
You do not need any additional or new software to convert to electronic data exchange for invoicing; only adaptations of the existing software will be necessary so that the new invoice formats can be generated, transferred and processed.
If you want to switch to e-Invoicing, you should first check the technical conditions of your company. For an effective transition, you need an electronic invoice receipt, a digital invoice workflow and an audit-proof archive within your company. In addition to the technical components, these are the main prerequisites for digitization. The AEI (= Association of Electronic Invoices) presents the usual project procedure for a conversion to e-invoicing in four steps:
INPOSIA is exactly the right partner for you if you want to switch your company to e-invoicing and digitize your business processes.
Then get in touch with our e-Invoicing experts! We are more than happy to help – via phone, email or in person at a location of your choice!
Muzaffer Havcarci
INPOSIA e-Invoicing Specialist
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