Electronic invoices Business to Government

Situation in Europa

Some countries introduced mandatory electronic invoices in the B2G sector, Denmark was the first in 2005, followed by Sweden 2008, Spain and Finland 2010 and Austria and Italy 2014.

Probably also because already in 2009, Denmark could credibly explain that the e-invoice saves them 100 million Eur/year. The predicted savings vary in a great bandwidth, in 2010 the European Commission referred to  a report
which indicates 226 billion Euro savings potential within six years (“assuming the best case scenario” and “a linear evolution”). In 2014, the EU finally decided in their 2014/55 EU Guideline to make the support of electronic invoices mandatory for all member states.

The EU legislation and Germany’s e-Rechnungsgesetz / e-Rechnungsverordnung define electronic invoices as structured, while the german law on VAT (Umsatzsteuergesetz) speaks of electronic invoices without further qualification and covers both structured and unstructured invoices. This unclear definition, often omitting the qualification “structured”, has caused some confusion, e.g. a german article stating that 68% of the participants in a survey do not know what electronic invoices are.

The European standardization authority CEN has published EN16931 to augment 2014/55/EU. From it’s five parts the first, EN16931-1, the list of qualified syntaxes and EN16931-2, the calculation rules, are available free of charge.

Germany national authorities started accepting electronic invoices as of November 2018 and made them compulsory as of November 2020 on a federal level as well as possible as of April 2021 on “subcentral” level (states, counties and cities).

Situation in Germany

In August 2018 there was a 1h (english) speech on the 13th Froscon outlining the situation. Feel free to have a look at the slides and/or the video recording:

As defined in the german e-invoice law (amended E-Rechnungsgesetz in Bgbl 19/2017) and the E-Rechnungsverordnung, structured e-invoices became mandatory vis á vis the national authorities (and Bremen) as of November 2020. The following states will follow: Baden-Württemberg and Saarland (as of 2022), Mecklenburg-West Pomerania as of April 2023, Rhineland-Palatinate as of 2024 and Hesse as of 18.04.2024 (german source).

All European formats providing the according attributes are allowed but the first german “country version” (i.e. CIUS) was the XRechnung, now also ZUGFeRD’s EN16931 profile is listed.

According to the justification for the e-Rechnungsverordnung the authorities receive an annual total of 7.95 million invoices, of which they expects 80% (6.36 million invoices) to become electronical.

The justification refers to the Architekturkonzept e-Rechnung, which estimates (page 96) 8 million invoices, half of which are direct and the other half are vis á vis the administration. Other sources talk about an potentially 300,000 stakeholders which may have been affected.

The official justification further expects a reduction of the processing time from 22,6 minutes to 11,78 minutes each and total savings of up to 62.38 million Euro for the government along with savings of 10.87 million Euro for the industry. The costs are expected to amount to 6.1 million Euro as a one off investment and 1.125 million Euro annually.

These 62.38 million is quite a lot but still much less than the 500 million expected in e.g. the Billentis E-invoicing business case, whichs says (page 21), “The difference to the total “public sector saving potential” above [in that case 6500-2600-3400] is the saving potential for the federal administration.”). The business cases also mentions a total “Minimum public sector saving potential” of 6.5 billion Euro per year just for Germany.