Electronic invoicing is governed by European Directive 2014/55/EU and the EN 1693 standard. These regulations are continually developing in European Union countries. Among them, Germany is a specific case, as its federal structure composed of 16 states (known in German as Länder) makes the process particularly complex. What particularities exist for e-invoicing in Germany? How does the system work? We’ve thumbed through current legislation and the technical aspects of the country.
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:
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.
After being divided into federal states, Germany encountered legislative issues when instituting electronic invoicing. Länder authorities and those present in the country are, however, very organized. In 2017, they called for implementation due dates regarding European regulation as it relates to e-invoicing, both in the public sector and municipalities. To go further in the digital transition, the country requires of its public entities that e-invoicing be independent from invoicing amount. This affords them a unique position within the EU. To learn more about the position of other countries in the European Union with regard to e-invoicing, take a look at our white paper.
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