Six key points on electronic invoicing in the federal administration
1. key point
The legal basis for electronic invoicing in Germany’s federal administration is the E-Invoicing Ordinance.
The Ordinance on Electronic Invoicing in Federal Public Procurement (E-Rechnungsverordnung, E-RechV) was adopted by the Federal Cabinet on 6 September 2017. The Ordinance specified the requirements of the E-Invoicing Act, thus completing the implementation of EU Directive 2014/55/EU in German federal law. It also obliged invoice issuers, with effect from 27 November 2020, to send electronic invoices to their customers in the federal administration.
The Ordinance specifies requirements for the invoice data model, which must conform to the XRechnung data exchange standard or another standard which complies with European standard EN 16931.
The Federal Central Invoice Submission Portal (ZRE) can be used to send e-invoices to the direct federal administration, while the Online Access Act-compliant Invoice Submission Portal (OZG-RE) is used to send e-invoices to more than 130 organisations of the indirect federal administration as well as to funding recipients and to five federal states. In future, the invoice submission portals will also be accessible via the federal administrative portal.
2. key point
A PDF invoice is not an e-invoice.
An electronic invoice (as defined in Directive 2014/55/EU and Germany’s E-Invoicing Ordinance) is an invoice that is created, sent and received in a structured electronic format. This format allows the invoice to be processed in an automated and electronic manner. An e-invoice consists of invoice data in a structured, machine-readable data file.
An image file, PDF file or scanned paper invoice does not meet these statutory requirements.
3. key point
E-invoicing allows seamless electronic processing from start to finish.
E-invoicing contributes to the digital transformation of the federal administration. An e-invoice sent to the federal administration should be processed electronically in full, from creation and processing to final payment and archiving. This seamless electronic processing eliminates the need to keep manual records. E-invoices, then, are a key component in the digital transformation of public invoicing and procurement processes. Current developments clearly demonstrate the benefits of digital business processes. Advances in digital technology make it easier to delegate tasks and perform them anywhere, and reduce processing times. E-invoicing plays an important role here, supporting administrative and business processes and allowing work to be conducted remotely.
4. key point
E-invoices must generally be issued using the XRechnung standard.
E-invoices for the federal administration must generally be issued using the current version of the XRechnung standard.
Note: Under the current concept of operations, the XRechnung standard is updated twice a year (on 1 February and 1 July) and published in the Federal Gazette and on the website of the Coordination Office for IT Standards (KoSIT).
Other standards may also be used as long as they meet the requirements of the European standard EN 16931, the terms of use for the federal invoice submission portals, and the requirements of the federal E-Invoicing Ordinance (e.g. ZUGFeRD version 2.2.0 or later in the XRECHNUNG profile).
The XRechnung standard was developed in a joint project of Germany’s federal administration and federal states. XRechnung is the national version of the European standard EN 16931, sponsored by the federal administration and federal states. Designed in a machine-readable data format, XRechnung enables invoice data to be imported directly and seamlessly into the relevant processing systems. The main purpose of the structured XML data file is to ensure machine-readability. XRechnung is intended to standardise the handling of electronic invoices in public administration. It is an open-source standard maintained by the Coordination Office for IT Standards (KoSIT). It is available free of charge and is adaptable to future needs.
All necessary information about the XRechnung standard can be found on the KoSIT website.
5. key point
Organisations of the direct federal administration receive e-invoices via the ZRE.
ZRE stands for Zentrale Rechnungseingangsplattform des Bundes, meaning “Federal Central Invoice Submission Portal”. Invoice issuers can use this portal to submit e-invoices to the direct federal administration.
The ZRE performs three tasks in the transmission of e-invoices:
- It receives e-invoices via various possible transmission methods.
- It checks e-invoices according to certain formal criteria (including invoice size, number and type of attachments, virus testing, completeness of mandatory information).
- It transmits e-invoices to their recipients using a buyer reference (Leitweg-ID).
To use the ZRE, invoice issuers must first register with the portal and create a user account. Registration is allowed for any natural person of legal capacity or any legal person (e.g. company). Registration is free of charge and is necessary no matter which method you choose for transmitting invoices. When registering, you must decide which method you will use to submit invoices, for example email or Peppol, and must specifically select this transmission method.
6. key point
Organisations of the indirect federal administration may receive e-invoices via the OZG-RE.
OZG-RE stands for Onlinezugangsgesetz-konforme Rechnungseingangsplattform, meaning “Online Access Act-compliant Invoice Submission Portal”. This portal can be used to receive e-invoices by authorities of the indirect federal administration (provided they fulfil the relevant requirements under public procurement law ). However, the use of this portal is not mandatory for authorities of the indirect federal administration; they are allowed to use their own solutions. A list of authorities that use the OZG-RE is available here (document available in German only).
If you are interested in using the OZG-RE, please get in touch with the support team using our contact form.
The OZG-RE essentially performs three tasks in the transmission of e-invoices:
- It receives e-invoices via various possible transmission methods.
- It checks e-invoices according to certain formal criteria (including invoice size, number and type of attachments, virus testing, completeness of mandatory information).
- It transmits e-invoices to their recipients using a buyer reference (Leitweg-ID).
To use the OZG-RE, invoice issuers must first register with the portal and create a user account. Registration is allowed for any natural person of legal capacity or any legal person (e.g. company). Registration is free of charge and is necessary no matter which method you choose for transmitting invoices. When registering, you must decide which method you will use to submit invoices, for example email or Peppol, and must specifically select this transmission method.
Background / further information
As of 2022, the federal administration and the federal states are obliged to offer administrative services in Germany in digital form via administrative portals, creating user-friendly services for use by private individuals, businesses and the administration. To this end, the 575 most important services must be made available online. In addition, the administrative portals are to be linked to a common network, through which all administrative services can be accessed.
The legal basis for this is the Act to Improve Online Access to Administrative Services (Gesetz zur Verbesserung des Onlinezugangs zu Verwaltungsleistungen, OZG), which entered into force in August 2017. The federal administration and the federal states are jointly responsible for implementing the OZG, including the digital transformation programme launched by the IT Planning Council to provide online services.
Further information is provided in the document „Seven tips for problem-free electronic invoicing with the federal administration“ in the library.