E-invoicing in Germany: focus on federal legi

What are the legal specificities of the country?

The main organization that manages promotion and standardization for e-invoicing in Germany is called the FeRD (Forum Elektronische Rechnung Deutschland). Much like the FNFE (Forum national de la facture électronique) in France, it groups together members of ministries, major public organizations and professional associations. On the scale of Länder, payment of invoices in an electronic format is managed by the German federal ministry of the interior.

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The legal framework was defined on April 4, 2017 by the German law on e-invoicing (E-Rechnungsgesetz), and has been in effect since September 2017 after being implemented by the Federal regulation on electronic invoicing (E-Rechnungs-Verordnung). These measures stipulate how receipt and handling should be performed for electronic invoicing by all federal contracting authorities independently of amount.

The law also calls for specific dates when electronic invoicing can be implemented: this has been true since November 27, 2018 for the highest federal authorities and as of November 27, 2019 for administrations in the public sector and for local and regional authorities.

As regards Länder, the directive is mostly transposed into additional legislation. Additionally, specific dates for electronic invoicing implementation may be prolonged until April 2020 at the latest.

Technical details for e-invoicing in Germany

Standards in effect

The XRechnung format is used for central, regional and local authorities, upon decision by the National German council for computerized planning. The European standard EN 16931 on semantics was adopted as part of directive 2014/55/EU on electronic invoicing on public markets. Note that a CIUS (core invoice user specification) is also included in the EN 16931: XRechnung XML standard. Other standards are also accepted:

• l’UBL-Invoice (Universal Business Language), adopted in version 2.1 (CUIS PEPPOL);

• le ZUGFeRD 2.0, known as Factur-X internationally – a French-German standard used for mixed invoicing.

E-invoicing in Germany: platforms used

As regards B2G invoicing, Germany has implemented a national platform for receipt of vendor invoices: the E-Rechnungs portal. It is used at the federal level and for some Länder, as the others have implemented their own solution. The platforms offer multiple ways to send invoices to government authorities: upload pages, online forms, e-mail transfer, EDI, APIs.

Participation in the PEPPOL network

Germany has decided to develop a Web interface with the PEPPOL network in April 2018. Although at first a mere evaluation period, the country chose to make its use mandatory in the future. The German branch of the network will operate under the authority of the coordination bureau for computing standards (KoSIT), also responsible for management of XRechnung.

Also read: E-invoicing: the Guarantees of PEPPOL Certification