Peppol e-invoicing in Germany
Germany's B2B e-invoicing mandate requires every business to accept structured e-invoices since 1 January 2025. Sending obligations are being phased in through 2028. Here is the full picture: the E-Rechnung definition, XRechnung vs ZUGFeRD, the Peppol network and what you need to do.
By Peppol Validator · Last updated · Auf Deutsch lesen
Current state, April 2026
Since 1 January 2025, every business registered for German VAT must be able to receive structured e-invoices. Sending e-invoices becomes mandatory for businesses with more than EUR 800,000 annual turnover from 1 January 2027. All remaining businesses must send structured e-invoices from 1 January 2028. B2G e-invoicing to federal authorities has been mandatory via Peppol and XRechnung since November 2020.
Mandate timeline
Germany's e-invoicing mandate was introduced by the Wachstumschancengesetz (Growth Opportunities Act), signed into law in March 2024. The rollout follows a phased approach. B2G requirements have been in place since 2020. The B2B mandate started with receiving obligations in 2025 and phases in sending obligations through 2028.
27 November 2020
B2G e-invoicing becomes mandatory. All suppliers to German federal authorities must submit structured e-invoices in XRechnung format via Peppol. The ZRE (Zentrale Rechnungseingangsplattform) serves as the central receiving platform.
1 January 2025
All B2B businesses must be able to receive structured e-invoices. The Wachstumschancengesetz requires every VAT-registered business in Germany to accept EN 16931-compliant e-invoices. No business may refuse an E-Rechnung from this date forward.
1 January 2027
Businesses with more than EUR 800,000 annual turnover must send structured e-invoices. This is the first phase of the sending obligation. Larger businesses must issue E-Rechnungen for all domestic B2B transactions.
1 January 2028
All businesses must send structured e-invoices. The sending obligation extends to all VAT-registered businesses regardless of size. Paper invoices and PDF-only invoices will no longer satisfy the requirements for B2B transactions.
1 January 2030
ViDA EU cross-border alignment. Germany aligns with the EU's VAT in the Digital Age (ViDA) regulation. Cross-border B2B transactions within the EU will also require structured e-invoices.
Who is affected?
The mandate applies to all businesses registered for German VAT. This includes companies, sole traders, freelancers and partnerships. Any entity that issues or receives VAT invoices for domestic B2B transactions in Germany falls under the mandate.
B2C transactions are excluded. Invoices to private consumers do not need to be structured e-invoices.
The Kleinunternehmerregelung (small business exemption under Section 19 UStG) does not grant an exemption from receiving. Small businesses that are VAT-exempt still must be able to accept structured e-invoices from 1 January 2025. They are, however, not required to send structured e-invoices until the general sending obligations apply to them.
What is an E-Rechnung?
The term E-Rechnung (electronic invoice) in Germany has a specific legal definition. It means a structured electronic invoice that conforms to the European standard EN 16931. The BMF (Bundesministerium der Finanzen, Federal Ministry of Finance) established this definition in the Wachstumschancengesetz.
A PDF is not an E-Rechnung. Neither is a scanned paper invoice or an image file. The invoice must be a machine-readable structured data file that software can process automatically without manual data entry.
This distinction is important. Many businesses that previously sent invoices as PDF attachments by email will need to switch to a structured format. The E-Rechnung requirement is about the data format, not just the delivery method.
Accepted formats
Germany accepts any structured e-invoice format that conforms to EN 16931. In practice, three formats dominate.
XRechnung
Germany's national CIUS (Core Invoice Usage Specification) of EN 16931. Uses CII (Cross Industry Invoice) XML syntax. Required for B2G invoicing to federal authorities. Maintained by KoSIT (Koordinierungsstelle fuer IT-Standards).
ZUGFeRD 2.x / Factur-X
A hybrid format that embeds a structured CII XML file inside a PDF/A-3 document. The PDF provides human-readable visualization while the XML carries the structured data. ZUGFeRD 2.x is a joint Franco-German standard, also known as Factur-X in France. The "Extended" and "XRechnung" profiles are EN 16931 compliant.
Peppol BIS Billing 3.0
The international Peppol format based on UBL 2.1 XML syntax. Fully EN 16931 compliant. Used for transmission over the Peppol network. Widely adopted across Europe and increasingly relevant for German B2B transactions.
Other EN 16931-compliant formats are also permitted by mutual agreement between buyer and seller. However, XRechnung, ZUGFeRD and Peppol BIS cover the vast majority of use cases.
B2G e-invoicing via Peppol
Germany's federal B2G e-invoicing has been operational since November 2020. The ZRE (Zentrale Rechnungseingangsplattform) is the central receiving platform for invoices to direct federal authorities. The OZG-RE platform serves indirect federal authorities and additional public entities.
Both platforms accept invoices via the Peppol network in XRechnung format. Suppliers connect through a Peppol Access Point to submit invoices to federal buyers. This established infrastructure laid the groundwork for the broader B2B mandate.
Individual German states (Bundeslaender) have their own B2G e-invoicing requirements and timelines. Some states mandate e-invoicing, while others still accept it voluntarily. Check your specific state requirements alongside the federal rules.
How to get compliant
Whether you already handle B2G e-invoices or are starting from scratch, here are the key steps to full compliance with the German E-Rechnung mandate.
- 1Set up e-invoice receiving. Since January 2025, your business must be able to receive structured e-invoices. Ensure your accounting or ERP system can accept and process EN 16931-compliant files. This is the most urgent step if you have not done it yet.
- 2Choose your sending format. Decide between XRechnung, ZUGFeRD 2.x or Peppol BIS Billing 3.0 for outgoing invoices. Consider your trading partners and their preferences. If you already invoice federal authorities, you likely have XRechnung capability in place.
- 3Connect to the Peppol network. Select a certified Peppol Access Point provider or verify that your accounting software includes Peppol connectivity. German software vendors such as DATEV, Lexware, sevDesk and Scopevisory increasingly offer built-in Peppol support.
- 4Ensure EN 16931 compliance. Your invoices must contain all mandatory fields: invoice number (BT-1), issue date (BT-2), seller and buyer identification, VAT registration numbers, line items with quantities and prices, VAT breakdown and payment terms.
- 5Validate before sending. Run your invoices through a validator to catch errors before they reach your customers. Check for CEN rules (BR-), Peppol-specific rules (PEPPOL-EN16931-) and XRechnung rules where applicable. Fix any issues flagged by the validator.
- 6Update internal workflows. Adapt your accounts payable and accounts receivable processes. Set up automatic booking of incoming e-invoices, reconciliation with purchase orders and compliant digital archiving per GoBD requirements.
Validate your invoices for free
Check your Peppol BIS 3.0 invoices against EN 16931 (CEN) and Peppol rules. Free, instant, no signup required.
Frequently asked questions
When does e-invoicing become mandatory in Germany?
Germany introduced its B2B e-invoicing mandate through the Wachstumschancengesetz (Growth Opportunities Act). Since 1 January 2025, all businesses must be able to receive structured e-invoices. Sending obligations are phased: businesses with more than EUR 800,000 annual turnover must send structured e-invoices from 1 January 2027. All remaining businesses must follow from 1 January 2028.
What is an E-Rechnung?
An E-Rechnung (electronic invoice) in Germany specifically means a structured electronic invoice that conforms to the European standard EN 16931. A PDF sent by email does not qualify as an E-Rechnung. The invoice must be a machine-readable structured data file in a format such as XRechnung, ZUGFeRD 2.x (Factur-X) or Peppol BIS Billing 3.0.
What is the difference between XRechnung and ZUGFeRD?
XRechnung is Germany's national CIUS (Core Invoice Usage Specification) of EN 16931. It uses CII (Cross Industry Invoice) XML syntax and is a pure XML format. ZUGFeRD 2.x (also known as Factur-X) is a hybrid format that embeds a structured XML file inside a PDF/A-3. Both are EN 16931 compliant. XRechnung is required for B2G invoicing to federal authorities. For B2B, both formats are accepted.
Does Germany use Peppol?
Yes. Germany has been using the Peppol network for B2G e-invoicing to federal authorities since November 2020. The ZRE (Zentrale Rechnungseingangsplattform) and OZG-RE platforms receive invoices via Peppol. For B2B e-invoicing, Peppol BIS Billing 3.0 is one of the accepted EN 16931-compliant formats. The Peppol network is expected to play a growing role as the B2B mandate fully rolls out.
Who is affected by the German e-invoicing mandate?
All businesses registered for German VAT are affected. This includes companies, sole traders and freelancers. B2C transactions are excluded from the mandate. Importantly, the small business exemption (Kleinunternehmerregelung under Section 19 UStG) does not exempt businesses from the obligation to receive structured e-invoices.
What formats are accepted?
Germany accepts any structured e-invoice format that conforms to EN 16931. The three main formats are XRechnung (CII-based XML), ZUGFeRD 2.x / Factur-X (hybrid PDF/XML) and Peppol BIS Billing 3.0 (UBL-based XML). All three satisfy the E-Rechnung requirement. Other EN 16931-compliant formats are also permitted by mutual agreement between buyer and seller.
How can I validate my German e-invoices?
Before sending an e-invoice, validate it against the EN 16931 (CEN) rules and the applicable format rules. Peppol Validator lets you check your UBL invoices for free, without signup. The tool verifies syntax, mandatory fields, business rules (BR-) and Peppol-specific rules (PEPPOL-EN16931-). For XRechnung-specific validation, use the XRechnung Validator.