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Germany XRechnung B2G e-invoicing with Frihet

Germany requires structured e-invoices for all public sector transactions and is rolling out mandatory B2B e-invoicing under the Wachstumschancengesetz. Frihet generates XRechnung-CII and XRechnung-UBL invoices, validates them against the KoSIT schema, and routes them to government recipients.

German e-invoicing rules stem from two legislative sources:

EU Directive 2014/55/EU — mandated that all EU member states accept structured e-invoices for B2G transactions from national, regional, and local authorities. Germany implemented this through federal law in 2020.

Wachstumschancengesetz (Growth Opportunities Act) — enacted March 2024, extends the obligation to B2B transactions:

DateObligation
1 January 2025All businesses must be able to receive EN16931-compliant e-invoices
1 January 2027Businesses with annual revenue > €800,000 must issue e-invoices
1 January 2028All remaining businesses must issue e-invoices

The B2B receive obligation started on 1 January 2025. If your German customer sends you a structured e-invoice, you are legally required to process it. Frihet handles incoming structured formats as attachments and flags them for reconciliation.

XRechnung — the mandatory standard​

XRechnung is the German national profile of EN16931. It defines strict implementation rules on top of the European semantic standard. Two technical syntaxes are accepted:

SyntaxFile extensionNotes
XRechnung-CII.xmlUN/CEFACT Cross Industry Invoice. Recommended by KoSIT for German B2G.
XRechnung-UBL.xmlOASIS UBL 2.1. Also valid; more common in multinational ERP systems.

Both syntaxes express the same semantic data model. The current version is XRechnung 3.0.2, governed by KoSIT (Koordinierungsstelle für IT-Standards).

Factur-X / ZUGFeRD 2.3 is also compliant with EN16931 and accepted in B2B contexts. It embeds an EN16931-CII XML inside a PDF/A-3 file, making it human-readable while remaining machine-processable. Frihet generates Factur-X hybrid PDFs for B2B invoices where requested.

Leitweg-ID — mandatory routing identifier for B2G​

Every XRechnung invoice sent to a German public authority must include a Leitweg-ID in the BuyerReference field (BT-10). This identifier routes the invoice to the correct administrative unit within the receiving authority.

The Leitweg-ID follows the format {section}-{subsection}-{check}, for example:

04011000-1234-06

Where:

  • 04011000 — administrative unit code (Behördenkennzahl)
  • 1234 — sub-unit or cost center
  • 06 — check digit
precaución

A missing or malformed Leitweg-ID causes automatic rejection at OZG-RE or the receiving authority's portal. Confirm the correct Leitweg-ID with your government customer's procurement office before invoicing.

Setting the Leitweg-ID in Frihet​

  1. Open the client record in Clients.
  2. In the Tax data section, enable Public authority (B2G).
  3. Enter the Leitweg-ID in the Leitweg-ID field.
  4. Save the client.

Frihet populates BT-10 with this value in every XRechnung generated for that client.

Generating XRechnung invoices in Frihet​

Once the client is configured:

  1. Create the invoice as usual.
  2. Open the completed invoice and click More options → Export e-invoice.
  3. In the export dialog (EInvoiceExportDialog), select XRechnung 3.0 (Germany).
  4. Choose the syntax: CII (recommended for B2G) or UBL.
  5. Download the .xml file.

Frihet validates the generated XML against the KoSIT schema rules before making it available for download. If the invoice data is incomplete (missing Leitweg-ID, missing VAT number, unsupported currency), the export dialog shows the specific error before generating the file.

KoSIT validator — pre-submission check​

The KoSIT validator is the official tool for verifying XRechnung conformance. Frihet runs the validation rules internally, but you can also verify the exported XML manually:

A compliant invoice produces a validation report with valid: true and zero errors.

Submitting to OZG-RE (federal authorities)​

The OZG-RE (Onlinezugangsgesetz — Rechnungseingang) is the federal government's central e-invoice receiving platform. It connects to the PEPPOL network for automated routing.

If your government customer uses PEPPOL routing:

  1. Your company needs a PEPPOL ID (e.g., 0088:DE123456789 or issued by a certified Access Point Provider).
  2. The receiving authority's PEPPOL ID appears in their procurement documents.
  3. Frihet routes the invoice via the PEPPOL network to OZG-RE.

PEPPOL AS4 transport for DE B2G is available in Frihet on Business+ plans. Contact support to activate your PEPPOL endpoint.

Via email transport (current default for ad-hoc B2G)​

For authorities not yet on PEPPOL, or for initial submissions:

  1. Export the XRechnung XML from Frihet.
  2. Email the .xml file to the authority's designated invoicing address (usually specified in the contract or purchase order).
  3. Some authorities use the ZRE (Zentrale Rechnungseingangsplattform) with a dedicated submission address.
PEPPOL AS4 deferred

Full automated PEPPOL AS4 transport for German B2G is in the Frihet Day 4 roadmap. Until activated for your account, email delivery is the supported path. The XRechnung XML generated by Frihet is technically correct for either transport method.

B2B obligations — what changes from 2025​

From 1 January 2025, every German VAT-registered business must be able to receive EN16931-compliant structured e-invoices. This means:

  • You cannot refuse a structured XML invoice from a German supplier.
  • Your accounting software must be able to parse XRechnung or Factur-X.
  • Frihet automatically handles incoming structured formats when connected via integration or API.

The emit obligation follows in 2027 (large companies) and 2028 (all others). Until those dates, you may continue issuing PDF invoices to German B2B customers, but you must be ready to transition.

Practical impact for Frihet users:

  • German customers will increasingly send you XRechnung or Factur-X XML files.
  • Use Frihet's expense import to attach and process these files against supplier records.
  • From 2027/2028, Frihet generates the mandatory structured format automatically for German B2B invoices.

Factur-X for B2B — hybrid PDF/A-3​

For German B2B invoices where the recipient prefers a human-readable document:

  1. In the export dialog, select Factur-X (Germany/France B2B).
  2. Frihet generates a PDF/A-3 file with the EN16931-CII XML embedded.
  3. The recipient's software can read the embedded XML automatically; humans can read the PDF.

Factur-X complies with both EN16931 and the Wachstumschancengesetz B2B requirements.

VAT and tax handling​

German e-invoices must include:

  • Supplier and buyer VAT numbers (BT-31, BT-48)
  • VAT breakdown per rate (BG-23)
  • Standard rates: 19% (general), 7% (reduced)
  • Zero-rated and exempt supplies require the applicable reason code

Frihet applies German VAT rates automatically when the invoice recipient has a German address. If your German customer is VAT-exempt (e.g., a public authority not subject to VAT), set the exemption in the tax configuration.

Frequently asked questions​

Does XRechnung replace the PDF invoice entirely? For B2G, yes — the PDF is no longer the primary document. The structured XML is the legally binding invoice. For B2B, PDFs remain acceptable until the emit mandate dates (2027/2028), but Factur-X allows you to send both simultaneously in one file.

What if my German customer sends a Factur-X file and I can not process it? From 1 January 2025, you are legally required to be able to receive it. Frihet's expense and supplier invoice management handles Factur-X ingestion. If you receive a file outside Frihet, you can upload it via the document import function.

Is my German VAT number sufficient as a PEPPOL identifier? No. Your PEPPOL ID is a separate identifier issued by a certified Access Point Provider (e.g., Pagero, Basware, Comarch). Your German VAT number (DE123456789) can form part of the ID under scheme 0088, but you need an Access Point to participate in the network.

Can I send XRechnung invoices to Austrian or Swiss public authorities? Austria uses a similar B2G mandate (ebInterface or PEPPOL UBL). Switzerland is not in the EU mandate scope. For cross-border B2G in other EU countries, Frihet generates the appropriate national profile.

Official references​