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E-invoicing FAQ

Here you will find useful questions and answers all about e-invoicing. Use the search function provided to find the answer to a specific question.

E-invoicing

What content requirements must be observed to create an e-invoice?

According toSection 5 of the Federal Government’s Regulation on Electronic Invoicing , in addition to VAT invoicing elements (for more on this, see Section 14 of the Value-Added Tax Act [UStG]), an e-invoice must contain the following information at a minimum:

Buyer reference – you will be given the buyer reference when the contract is awarded.
Terms of payment (payment due date or text description of the terms)
The payment recipient’s bank details
The invoice issuer’s postal or De-Mail address

Mandatory information according to Section 5 E-RechV of the Federal Government	To be entered in the following elements of an XRechnung invoice (cf. XRechnung V.1.1)
Buyer reference	BT-10 BT = Business term or information item
Bank details	For Bank transfer: BG-17 (BT-84 to 86) For direct debit: BG-19 (BT-89 to91) BG = Business group or group of information items
Terms of payment	BT-9 or BT-20
Email or De-Mail address	BT-43
Supplier number*	BT-29
Purchase order number*	BT-13

*Mandatory information, if transmitted at the time of commissioning

A specific data field is provided for each of these additional details. Further information on the XRechnung invoice standard can be found in the FAQ section on XRechnung invoicing.

What is an e-invoice?

An e-invoice is invoice information that is transmitted electronically and automatically received and processed. An e-invoice facilitates consistent, automated transmission and processing of invoice information from the invoice submission to payment.

An e-invoice provides invoice content in a structured, machine-readable data set instead of on paper or in an image file such as a PDF. This ensures that information provided in this form by the invoice issuer can be:

a) transmitted electronically

b) received electronically

c) as well as processed and approved for payment automatically and seamlessly.

Paper, PDF and e-invoice differences

Which formal requirements must be observed for the creation of e-invoices?

The latest version of the XRechnung standard must always be used when issuing e-invoices. Another standard (e.g. ZUGFeRD 2.1.1 XRechnung profile without PDF visual format, as a purely structured XML file) can also be used if it complies with the requirements of the European standard for electronic invoicing (EN-16931), the Federal Government’s Regulation on Electronic Invoicing (E-RechV) and the Federal Government’s terms of use for the invoice submission platforms.
Invoice formats that do not comply with the requirements of the European standard cannot be taken into account.
Invoice supporting documents or attachments must be embedded in the invoice data record and may not be sent separately as an attachment to an email or De-Mail.
The maximum permissible size of an invoice depends on the transmission channel selected (e.g. for ZRE: 10 MB for email attachments or 11 MB for attachments in the web entry). Please refer to the terms of use of the platform. The maximum number of embedded documents supporting the invoice is limited to 200. Permitted file types of the embedded documents are: ‘png’, ‘pdf’, ‘jpg’, ‘jpeg’, ‘xlsx’, ‘ods’ and ‘csv’.“. Attachments may not contain active content (e.g. macros). Changes to these restrictions will be announced via the invoice receipt platforms.
Invoice documents with attachments that require paper-based submission under other legal provisions (export certificates, customs documents, etc.) remain unaffected by the above regulations.
More detailed information on the XRechnung standard can be found at KoSIT.

Can I send a PDF as an e-invoice?

No. As defined in EU Directive 2014/55/EU, e-invoicing is a structured data set. A PDF file is not an e-invoice under these requirements.

Do I have to submit my invoices electronically to the Federal Government?

In principle, the obligation for contractors to invoice the Federal Government electronically applies from 27/11/2020. The exceptions are regulated in the ordinance and are described as follows:

Invoices issued after the fulfilment of a direct order up to an amount of 1,000 euros (order value)
Invoices subject to the exceptions under Section 8 or Section 9 (confidential invoice data as well as matters of the European External Action Service and other procurements abroad)
Invoices to be issued in procedures for the borrowed administration arrangement under Section 159(1)(5) of the Act against Restraints of Competition (GWB).
Irrespective of the legal obligation, an obligation to submit e-invoices may also arise from the respective underlying order or contractual relationship.

Download Regulation on Electronic Invoicing (E-RechV)

Do I have to use a special program to create e-invoices?

No! A special program is not required. There are several options for creating an electronic invoice to authorities of the Federal Administration, in particular:

Use of an (ERP) system or service provider
Do you use a service provider or commercially available software for invoicing? Contact the manufacturer and find out whether electronic invoicing is supported. Do you use your own system? Clarify with your IT department which steps are necessary to create e-invoices that are compliant with the EU standard.
Use of the ZRE/OZG-RE web-based entry system
If you are not using an outgoing invoice system or if you need an interim solution, familiarise yourself with the ZRE/OZG-RE web-based entry system. On both platforms, the Federal Government provides functions for manual entry of invoices. Templates can also be created and downloaded for later use or reuse.

How does my e-invoicing get to the right recipient?

The following federal invoice receipt platforms must be used for submitting e-invoices.

Direct Federal Administration institutions and federal constitutional bodies are connected to the CISP/ZRE.
Invoices to bodies of the indirect Federal Administration (and to cooperating federal states) are submitted via the OZG-RE platform.
Note: Indirect Federal Administration public contracting authorities are not obliged to use the OZG-RE, which is why in-house solutions are also possible in individual cases in addition to OZG-RE. The contracting authority will inform its invoice issuers about the invoice submission method to be used.

You can obtain more detailed information (for example, which platform is available to you) via the underlying order or, of course, directly from the invoice recipient.

In addition, we offer an overview of the contracting authorities connected to the two platforms on the website (section ‘Invoice issuers – General information on e-invoices’). It does not replace bilateral communication with your ordering party to provide further information such as buyer references.

The two central platforms require prior registration and activation of the desired transmission channels for the transmission of the invoice. For high invoice volumes, the mass transmission channels web service via Peppol, email and, in the future, De-Mail are suitable. Alternatively, the upload and web entry functions are also available. Make sure you identify the transmission channel that suits you best.

Download decision assistance for selecting a transmission channel (DE)

What information is available in English?

The following English language documents are available for foreign invoice issuers:

Download supplier Information (supplier communication, short description)

Download brochure for billers (booklet for invoice issuers, detailed description)

Download the terms of use of the OZG-RE

Download the terms of use of the CISP/ZRE

Download CISP/ZRE operating guide

Efforts are currently underway to provide English-language navigation within the platforms.

How is e-invoicing organised at federal and state level?

The Federal Government’s E-Invoicing Act and the Federal Government’s Regulation on Electronic Invoicing govern the exchange of invoices between the direct and indirect Federal Administration and its suppliers. The individual federal states have the authority to implement EU Directive 2014/55/EU.

From 27 November 2020, apart from a few exceptions, the Federal Government will require its suppliers to submit e-invoices. The electronic invoicing requirements applicable to you, as a supplier to federal state authorities and companies, will be regulated in the respective statutory provisions of the states.

At federal state level, the CISP/ZRE (direct Federal Administration) and OZG-RE (indirect Federal Administration) invoice submission portals are provided for the exchange of invoices. The federal states can also connect to the OZG-RE but provide their own invoice submission solutions as well.

The table below lists websites providing information about e-invoicing within the respective federal states, and is therefore an initial aid to obtaining an overview of the local implementation. For more information, see the KoSIT Country Comparison. If you have doubts about the legal situation, we recommend addressing your questions to your contracting authority within the state administration directly.

List of information websites about e-invoicing in the states

Federal state	Information site (incl. link)
Baden-Württemberg	service-bw.de
Bavaria	e-rechnung.bayern.de
Berlin	berlin.de/e-rechnung
Brandenburg	mdfe.brandenburg.de
Bremen	e-rechnung.bremen.de
Hamburg	Further information to follow
Hessen	verwaltungsportal.hessen.de
Mecklenburg-Western Pomerania	mv-serviceportal.de
Lower Saxony	rechnung.niedersachsen.de
North Rhine-Westphalia	vergabe.nrw.de
Rhineland-Palatinate	e-rechnung.rlp.de
Saarland	e-rechnung.saarland For information about the user account and terms of use: e-rechnung.service.rlp.de
Saxony	egovernment.sachsen.de
Saxony-Anhalt	Further information to follow
Schleswig-Holstein	Further information to follow
Thuringia	finanzen.thueringen.de

Current information

Electronic invoicing is becoming standard procedure for companies and government administration.

All 104 institutions of the direct federal administration, as well as the federalministries and federal offices, receive electronic invoices via the...