Germany B2G E-Invoicing: Public Sector Requirements

Germany has specific e-invoicing requirements for B2G transactions. For suppliers to the federal administration, electronic invoicing has been mandatory since 27 November 2020 under the Federal E-Rechnungsverordnung (ERechV), subject to specific exceptions. 

Unlike a standard commercial invoice, a B2G e-invoice must meet specific format, data, routing, and submission requirements. XRechnung is the main format used for public-sector invoicing, while the Leitweg-ID helps route the invoice to the correct public authority.

What is Germany's B2G e-invoicing?

Germany's B2G e-invoicing is the electronic invoicing process used when businesses bill public-sector authorities. For suppliers to the federal administration, electronic invoicing has been mandatory since 27 November 2020 under the E-Rechnungsverordnung (ERechV), subject to specific exceptions.

B2G invoices must use a permitted structured format, contain the required invoice data, include the correct Leitweg-ID for routing, and be submitted through the channel accepted by the relevant authority. XRechnung is the main standard used for German public-sector invoicing.

B2G requirements are separate from Germany’s phased B2B e-invoicing rules. State and municipal authorities may also have different submission requirements, so suppliers must check the rules that apply to each public-sector customer.

Who Must Issue B2G E-Invoices

The federal B2G e-invoicing requirement applies to suppliers issuing invoices to the German federal administration. Under the ERechV, covered suppliers must submit invoices electronically when the transaction falls within the federal B2G framework and is not covered by an applicable exception.

This federal requirement covers invoices to federal authorities and other recipients within the scope of the ERechV. It is separate from Germany’s B2B e-invoicing rules under the UStG. The fact that a customer is a public authority does not, by itself, determine which rules apply.

• Format: The structured invoice format accepted by the public authority.
• Leitweg-ID: The routing identifier provided by the contracting authority.
• Submission channel: The portal or transmission method specified for that recipient.
• Procurement references: Required purchase order, contract, supplier, or other reference numbers.

Note: A single B2G process cannot be assumed to apply across federal, state, and municipal customers because the applicable requirements and submission infrastructure can differ. 

Germany B2G E-Invoicing Legal Requirements

The federal B2G framework is primarily governed by the Federal E-Rechnungsverordnung. The electronic invoicing obligation has applied to federal suppliers since 27 November 2020, subject to specific exceptions.

B2G invoices to public administration do not automatically fall under the VAT e-invoicing mandate when the public body is not acting as an entrepreneur. A separate electronic invoicing obligation may still apply under the ERechV.

Businesses must therefore assess B2G requirements under the ERechV separately from the VAT e-invoicing rules under the UStG.

When is a B2G e-invoice not required?

The federal ERechV provides exceptions to the electronic invoicing obligation. One exception applies to Direktaufträge with an expected order value of up to €1,000 excluding VAT under the applicable procurement rules. This does not mean that every government invoice below €1,000 is exempt.

Other ERechV exceptions cover certain transactions involving confidential information, foreign procurement or services, and specific organisational arrangements.

Public authorities may also specify additional invoice data or procurement references. Suppliers must follow the requirements applicable to the relevant contract and authority.

Which e-invoice format is required for German B2G?

XRechnung is the principal standard for federal B2G e-invoicing in Germany. It implements the EN 16931 semantic model with Germany-specific business rules and is provided as structured XML. A generic XML file is not sufficient. The invoice must comply with the applicable XRechnung, EN 16931 and platform validation requirements.

Can ZUGFeRD be used for B2G invoices?

ZUGFeRD 2.2.0 in the XRECHNUNG profile can be used for federal B2G invoicing where the applicable requirements are met. For federal submission, the XRECHNUNG profile is accepted as a purely structured XML file without the visual PDF component. 

Suppliers should not assume that every ZUGFeRD profile is accepted. The applicable authority requirements must be checked before submission.

Is a PDF valid for German B2G invoicing?

A standard PDF does not satisfy the requirement. A compliant structured invoice format must be submitted; where permitted, supporting documents can accompany the structured invoice. 

Suppliers must submit the required structured invoice. A PDF may be provided as supporting documentation where permitted, but it does not replace the structured invoice data.

Required B2G Invoice Information

A B2G invoice must contain the applicable VAT invoice information under §14 UStG and the additional information required by the federal ERechV.

Note: In addition to the applicable VAT invoice requirements, the federal ERechV specifies additional information for B2G invoices. The following table highlights key ERechV-specific fields; it is not an exhaustive list of XRechnung requirements. 

What is a Leitweg-ID and where does it go?

The Leitweg-ID is the routing identifier for the public-sector recipient. It directs the invoice to the relevant authority or internal processing unit. The contracting authority provides the applicable Leitweg-ID to the supplier. In XRechnung, the Leitweg-ID is entered in BT-10, Buyer Reference.

A wrong Leitweg-ID can result in incorrect routing or rejection. An authority may use multiple Leitweg-IDs for different internal processing areas. Suppliers should use the identifier specified for the relevant order.

Leitweg-ID vs Peppol ID

The Leitweg-ID identifies the public-sector recipient within the German government invoicing environment. A Peppol Participant ID identifies a participant on the Peppol network.

For OZG-RE-connected federal entities, a Peppol participant identifier can be constructed using the 0204 scheme together with the relevant Leitweg-ID. The two identifiers serve different purposes.  Enterprise systems should maintain Leitweg-ID and Peppol Participant ID as separate master-data fields, even when one is derived from the other for a specific transmission channel.

How are B2G e-invoices submitted in Germany?

The submission channel depends on the public authority and its technical infrastructure.

For the direct federal administration, OZG-RE is the central and mandatory invoice submission platform. It is also used by connected organisations in the indirect federal administration and cooperating states The ZRE was subsequently taken out of service for invoice receipt and shut down at the end of 2025.

Depending on the applicable federal setup and recipient, transmission methods can include portal submission, file upload, and Peppol. Suppliers must use a submission channel accepted by the specific recipient.

How does B2G invoice validation work?

B2G invoices should be validated before submission to the public authority. Validation checks the invoice structure, required fields, business rules, tax data, and recipient information to identify errors that could lead to rejection. 

1. Syntax validation
   Confirm that the XML conforms to the applicable technical syntax.
2. Semantic validation
   Confirm that invoice data is mapped to the correct EN 16931 and XRechnung business terms.
3. Business-rule validation
   Check mandatory fields, VAT calculations, references, and logical relationships against the applicable rules.
4. Recipient validation
   Verify the Leitweg-ID, purchase order number, and other recipient-specific requirements.

Note: The BMF recommends validating an e-invoice before creation and submission to identify missing or inconsistent information. 

What happens when a B2G e-invoice is rejected?

B2G e-invoices can be rejected for technical or data errors, such as an invalid Leitweg-ID, missing order references, incorrect tax data, invalid XML structure, or missing mandatory fields, making automated validation, error handling, resubmission, and status tracking essential for high-volume operations.

• Review the rejection: Identify the failed field, validation result, or recipient requirement.
• Correct the source data: Update the ERP or billing system so the correction is reflected in subsequent invoices.
• Regenerate and validate: Generate the corrected structured invoice and validate it against the applicable XRechnung, EN 16931, and recipient requirements.
• Resubmit the invoice: Use the prescribed submission channel and correct recipient information.
• Retain the audit trail: Keep the original invoice, rejection response, corrected invoice, and submission status with the invoice record.

What should enterprises consider when implementing B2G e-invoicing?

For finance and IT teams, the primary implementation challenge is the control architecture around the invoice, not the XML format alone.

1. Map the public-sector customer

Maintain the authority's legal entity, authority level, Leitweg-ID, required references, format requirements, and submission channel in customer master data.

2. Map ERP data to the invoice model

Ensure that the ERP or billing system supplies all mandatory invoice data. Avoid manual entry of routing identifiers and procurement references at high transaction volumes.

3. Validate before transmission

Automate checks for XRechnung syntax, EN 16931 business rules, VAT data, Leitweg-ID, and recipient-specific requirements.

4. Automate submission and status handling

Record whether each invoice was generated, validated, transmitted, accepted, rejected, or returned by the receiving infrastructure.

5. Control corrections

Maintain the relationship between the original invoice, rejection reason, corrected invoice, and subsequent submission.

6. Archive audit evidence

Retain the structured invoice and relevant evidence showing what was issued, when it was transmitted, and how it was processed.

B2G vs B2B e-invoicing in Germany

B2G and B2B e-invoicing in Germany follow different legal frameworks. B2G requirements apply to covered public-sector invoices under the ERechV, while B2B e-invoicing is governed by the phased UStG rules. 

B2G and B2B VAT e-invoicing rules operate alongside each other. ERP and e-invoicing architectures should maintain separate rule sets for the two transaction types.

Conclusion

For federal B2G invoicing, compliance extends beyond generating an XRechnung. Enterprises need accurate recipient and Leitweg-ID data, compliant structured invoice content, validated submissions, controlled exception handling, and a complete invoice record. Because submission requirements differ across federal, state, and municipal environments, these controls should be mapped to the specific public-sector customer and transmission channel. 

Frequently asked questions

Is B2G e-invoicing mandatory in Germany?

For suppliers to the federal administration, electronic invoicing has been mandatory since 27 November 2020, subject to the exceptions defined by the ERechV. State and local requirements must be assessed separately.

Is XRechnung mandatory for B2G invoices?

XRechnung is the principal German public-sector e-invoice standard. The permitted format can depend on the applicable authority and federal requirements.

Who provides the Leitweg-ID?

The contracting authority provides the relevant Leitweg-ID to the supplier. Suppliers do not normally apply for their own Leitweg-ID.

Is OZG-RE the B2G portal for all of Germany?

No. OZG-RE is the federal invoice-entry platform. State and municipal authorities may use different systems and submission arrangements.

Is Peppol mandatory for German B2G invoicing?

No. Peppol is a transmission network, not a universal German B2G requirement. Its use depends on the applicable recipient and submission infrastructure.