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. For the deadlines by business size, see the E-Rechnung-Pflicht overview.
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.
XRechnung, ZUGFeRD and Peppol: 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. For a side-by-side comparison, see ZUGFeRD vs Factur-X vs XRechnung.
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.
Peppol ID in Germany: Leitweg-ID vs participant identifier
Two identifiers are easy to confuse when you start sending Peppol-compliant e-invoices in Germany. Getting them right is what makes an invoice route to the correct recipient.
The Leitweg-ID identifies a public authority (the buyer) for B2G invoicing. It is entered as the Buyer reference (BT-10) and, under Peppol scheme 0204, also acts as the authority's routing address on the ZRE and OZG-RE platforms. Each authority issues its own Leitweg-ID, so you request it from the public buyer, not from Peppol.
Your Peppol participant identifier is your own address on the network. You do not apply for it separately: when you register with a certified Peppol Access Point, the provider assigns and publishes it. For German companies this is usually the VAT number under Peppol scheme 9930 (DE:VAT). You need the recipient's Leitweg-ID to address a B2G invoice, and your own participant ID to transmit it.
People also ask: XRechnung and Peppol in Germany
Quick, direct answers to the questions people ask most about e-invoicing in Germany and how XRechnung relates to Peppol.
Is e-invoicing mandatory in Germany?
Yes, e-invoicing is mandatory in Germany and is being phased in under the Wachstumschancengesetz (Growth Opportunities Act). Since 1 January 2025 every VAT-registered business must be able to receive structured e-invoices. Sending becomes mandatory for businesses above EUR 800,000 annual turnover from 1 January 2027, and for all remaining businesses from 1 January 2028. B2G e-invoicing to federal authorities has been mandatory via Peppol and XRechnung since November 2020.
What is the difference between XRechnung and Peppol BIS?
XRechnung is a German invoice specification, while Peppol BIS Billing 3.0 is an international specification paired with a delivery network. XRechnung is Germany's national CIUS of EN 16931 and can be expressed in UBL or CII syntax. Peppol BIS is the UBL-based EN 16931 profile used to exchange invoices over the Peppol network. The two are not mutually exclusive: an XRechnung in UBL syntax can be carried as a Peppol BIS document.
Can I send XRechnung invoices over Peppol?
Yes, you can send XRechnung invoices over the Peppol network. XRechnung in UBL syntax is compatible with Peppol BIS Billing 3.0, so it can be transmitted through a certified Peppol Access Point. This is exactly how German B2G invoices reach the federal ZRE and OZG-RE platforms today. The Access Point routes the invoice to the recipient's Peppol address.
What format does Germany require for e-invoices?
Germany requires a structured e-invoice format that conforms to the European standard EN 16931. The three formats that satisfy this are XRechnung, ZUGFeRD 2.x / Factur-X and Peppol BIS Billing 3.0. A plain PDF or a scanned paper invoice does not qualify as an E-Rechnung. XRechnung is mandatory for B2G invoicing to federal authorities, while B2B accepts any EN 16931-compliant format.
Do German B2B companies need Peppol?
No, German B2B companies are not legally required to use Peppol. The law mandates the e-invoice format (EN 16931) but not the transmission channel, so e-invoices may be sent via Peppol, email, web upload or DE-Mail. However, Peppol is a standardized, secure channel that is increasingly adopted, and it is already the established route for B2G invoices to federal authorities.
Need to check a file? Use the E-Rechnung Validator for XRechnung and ZUGFeRD, or read the guide E-Rechnung in Deutschland auf Deutsch.
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.
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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 do I get a Peppol ID in Germany?
German businesses do not apply for a Peppol ID directly. You register with a certified Peppol Access Point, which assigns your Peppol participant identifier and publishes it in the network. For German companies this identifier is usually the VAT number (Peppol scheme 9930, DE:VAT). This is different from the Leitweg-ID, which is a routing address issued to each public authority for B2G invoicing and is not something a supplier obtains.
What is the difference between a Leitweg-ID and a Peppol ID?
A Leitweg-ID identifies the public-authority buyer and routes a B2G invoice to the correct German administration. It is entered as the Buyer reference (BT-10) and, under Peppol scheme 0204, also serves as the authority's Peppol routing address on the ZRE and OZG-RE platforms. A Peppol participant ID identifies you, the sender, on the Peppol network and is typically your VAT number (scheme 9930). You need the recipient's Leitweg-ID to send a B2G invoice, and your own Peppol participant ID to transmit it through an Access Point.
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.