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Digitalisation

Understanding B2G E-Invoicing in Germany: A Comprehensive Guide (1/5): A Look Back at B2G E-Invoicing in Germany

January 31, 2024
3
Minutes reading time

Explore the world of e-envoicing in Germany! Our latest blog series will guide you through the various portals and transmission methods in the German B2G e-invoicing system. Learn how to efficiently and compliantly send invoices to public authorities.

This article was last updated on 12 May 2025 to reflect the upcoming consolidation of the ZRE and OZG-RE invoice submission platforms.

Per EU Directive 2014/55/EU on electronic invoicing in public procurement, Germany has mandated public authorities, through its E-Invoicing Ordinance (ERechV), to gradually accept e-invoices in the XRechnung format or other formats compliant with the European standard on eInvoicing, from their contractors. This began in November 2018 for federal authorities and a year later in November 2019 for sub-central, sectoral, and concessionary authorities.

Finally, on November 27, 2020, the obligation for invoice issuers to issue invoices electronically came into effect. Exceptions to this obligation are regulated in the ordinance and include, amonth other things, invoices for direct orders up to an amount of €1,000 (order value).

Parallel to the ongoing discussions surrounding the Growth Opportunities Act, including the proposal for mandatory electronic invoicing between businesses (B2B), we are now delving deeper into the topic of electronic invoicing in the B2G sector. In the following blog series, we will shed light on various aspects of this German B2G e-invoicing obligation, which is already in force. Today, we start with an overview of the different portals and transmission methods used for invoicing public authorities in Germany.

In the next few issues, we will take a closer look at the different invoicing standards, examine the Leitweg-ID (a routing ID used specifically in German B2G e-invoicing) in detail, take a closer look at Peppol in the context of the German B2G e-invoice, and look at the status of the introduction of mandatory e-invoicing in the individual federal states. Finally, we will take a closer look at how our all-in-one solution for SMEs, Banqup, can help you submit your invoices to the German authorities in compliance with the law.

A variety of portals

The German federal administration currently uses two national portals for e-invoicing: The ZRE (Zentrale Rechnungseingangsplattform des Bundes or Central Invoice Submission Platform) and the OZG-RE (Onlinezugangsgesetz-konforme Rechnungseingangsplattform or Online Access Act-compliant Invoice Submission Platform). However, as announced on 19 November 2024 by the Federal Ministry of the Interior (BMI) and the Federal Ministry of Finance (BMF), these two platforms will be consolidated in 2025. The ZRE, which allows organisations within the direct federal administration to receive e-invoices, will be merged into the OZG-RE, which is currently available to organisations of the indirect federal administration and cooperating federal states. Organisations of the indirect federal administration may continue to operate their own solutions for receiving e-invoices, provided they comply with the Ordinance on Electronic Invoicing in Federal Public Procurement (E-Invoicing Ordinance - ERechV).

These are the two current invoice portals used by the direct federal administration, parts of the indirect federal administration, and some participating federal states. In addition, there are numerous independently operated platforms. Before sending an invoice, make sure you are using the correct portal and confirm this with your customer.

Consolidated federal invoice submission platforms

To support the federal administration (e.g. federal ministries and top-level federal authorities) in receiving e-invoices, the Central Invoice Submission Platform (Zentrale Rechnungseingangsplattform des Bundes, short ZRE) was initially developed. This is a web-based application that allows suppliers and service providers to send e-invoices to the relevant federal authority.

For the submission of invoices to the institutions of the indirect federal administration and states connected to the system, a separate portal has been developed: the Online Access Act- or OZG-compliant Invoice Submission Portal (OZG-RE).

As already mentioned, the ZRE and OZG-RE will be merged into a single platform – the OZG-RE – in 2025. This decision was made by the Federal Ministry of the Interior (BMI) and the Federal Ministry of Finance (BMF). The aim of this consolidation is to provide a uniform access point for invoicing across the federal administration, thereby reducing effort and complexity for suppliers.

In future, the OZG-RE will serve all organisations within the federal administration. All technical invoice recipients within the direct federal administration must be connected to the OZG-RE. The authorities affected were informed at the beginning of 2025, and a pilot phase with selected authorities will take place in spring 2025. The actual onboarding will occur in two waves, with the first wave scheduled for 20 June 2025.

Suppliers will be informed by their respective public authorities about the exact switchover date and will receive all necessary details. Registration with the OZG-RE is already possible via OZG-RE - Anmeldung (Registration). Once the transition is complete, the ZRE will no longer be available.

Other

Due to Germany's federal structure, the transposition of the EU directive into national law is inconsistent and must be carried out separately by the federal government and the 16 federal states. As a result, there may be different requirements for e-invoicing for suppliers due to the respective state regulations - such as the permissible formats (in accordance with European standard 16931) or transmission methods, as well as monetary thresholds.

At the request of invoice issuers, the Federal Ministry of the Interior and Community has published an overview of the information on e-invoicing provided by each federal state on its e-invoicing website, to provide an initial overview of the implementation. However, no guarantee can be given for the completeness, timeliness, and accuracy of the information provided by each federal state. Further information can be found in the KoSIT state synopsis (Ländersynopse, available in German)

If you are unsure about the legal situation and the routing ID (i.e. the buyer reference serving to uniquely identify the respective recipient) to be used, we recommend that you contact your customers in the state administrations directly.

Transmission methods

Customers connected to one of the federal government's two invoice submission portals (currently either the ZRE or the OZG-RE, which will be consolidated into a single platform in the course of 2025) have four basic options for submitting e-invoices. These options are described in more detail below.

  1. Peppol:

As part of the implementation of Directive 2014/55/EU on electronic invoicing in public procurement in Germany, the National IT Planning Council decided that public bodies in Germany must be reachable via the Peppol network if they offer a web service for e-invoices.

Peppol is indeed the preferred delivery method for the future unified federal platform, and it is the only channel that supports fully automated exchange of electronic documents and the submission of large volumes of invoices. This brings additional advantages such as greater efficiency, improved quality, and enhanced security.

To submit invoices via Peppol, suppliers can choose to use the federal Peppol web service (known in German as Peppol des Bundes), use an existing Peppol service provider such as Unifiedpost and our SME solution Banqup, or join OpenPeppol and set up their own Peppol access point.

  1. Email or De-Mail (the state-certified service for legally secure communication on the Internet):

When using email, it is important to observe the restrictions imposed by the federal authorities, such as each email may only contain one invoice and that "no reply" email addresses may not be used.

Regardless of whether you currently send invoices via the ZRE or the OZG-RE (and whether you use standard e-mail or De-Mail, the e-government communication service available for the ZRE), the first step in both cases is to register with the chosen submission portal. Comprehensive documentation is available for both options to guide you through the electronic invoice submission process. Both platforms also offer a test environment where users can practise submitting invoices - this will remain in place even after the portals are consolidated.

  1. Web capture:

Both the ZRE and the OZG-RE currently allow invoice data to be entered manually into a web form in the browser. This method is suitable if you do not have your own software for generating e-invoices or if you only need to submit a limited number of documents.

  1. Manual upload:

E-invoices created in another system using the XRechnung standard can be submitted to both the ZRE (until the upcoming consolidation) and the OZG-RE via manual upload. This method is recommended alongside web-based submission when there is no dedicated e-invoicing software available or when only a small number of documents need to be submitted.

We hope that you have enjoyed this first step in exploring the world of B2G e-invoicing in Germany and that you have gained valuable insights into the regulations, portals and transfer methods. But this is only the beginning. Stay tuned for our next posts, where we will dive deeper into invoicing standards, all things Leitweg ID, Peppol in the context of German B2G e-invoicing and the status of the e-invoicing regulation in the individual federal states. You will also learn how our all-in-one solution for SMEs, Banqup, can optimise your invoicing process to meet the requirements of the German authorities.

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