Electronic Invoices Becoming Obligatory in German Public Sphere

  • eco Association welcomes Ministry of the Interior’s draft legislation

  • Finally investment security for digital transformation in companies

A breakthrough in Berlin for electronic invoices: The public sector wants to create the possibility and the obligation to submit electronic invoices to public contracting bodies as of autumn 2018. Proposed legislation to this effect was presented by German Federal Ministry for the Interior (BMI) in June 2017. This is to be possible either in the German format XRechnung or in compliance with the new standards of the European norm EN 16931 (CEN TC 434).

Specialists and associations are now called upon to comment on this “Draft regulation on the electronic invoicing in public procurement for the federal government”. “We welcome greatly the fact that a resilient regulation has now been defined,” says Prof. Dr. Georg Rainer Hofmann, Leader of the Competence Group e-Commerce in eco – Association of the Internet Industry. “Electronic invoicing is central for the successful digital transformation of the economy and administration.”

Investment security for electronic invoicing processes

Florian Kohl, Member of the Federal Board of the Junior Chamber of Commerce Germany, also sees the draft law as a big step in the right direction: “The electronic invoice will become obligatory in the public sector – this will result in a range of positive ecological effects, as well as savings in the cost of processing.” Given that the Interior Ministry has recognized the European norm EN 16931 as well as the XRechnung, a long-winded discussion as to the preferred standard has now been ended. “Companies that wish to optimize their processes by using electronic invoicing now finally have investment security,” says Professor Hofmann.

Especially from the German perspective, the decision of the European Committee for Standardization (Comité Européen de Normalisation, CEN) is pleasing. The norm EN 16931 of CEN TC 434 contains important elements of the German national technical format ZUGFeRD, which was developed in Germany by the Working Group for Economic Administration (AWV).

Interior Ministry must improve quality assurance

For all the pleasing developments, there is still quite a bit to do, according to Hofmann. For example, the public sector would need to expand the possibilities to submit e-invoices: “So far, the submission of an e-invoice has been provided for over the access portal in accordance with the Online Access Act. However, it would be more efficient to make appropriate, reliable APIs (Application Programming Interfaces) generally available.”

Hofmann sees further need for action in the guarantee of the functionality and the reliability of the administrative system for e-invoices. With the norm EN 16931, the European Committee for Standardization has so far only published Part 1 on semantic data models and Part 2 on the syntax of electronic invoicing. However, a testing standard that ensures the quality of the IT systems for electronic invoicing would be advantageous.

A further open question relates to the threshold for electronic invoicing. Here, the eco Association recommends setting this to € 0.00, to prevent a splitting of invoices. Also to be clarified are the inclusion and conversion of other formats used within Europe, such as from Scandinavia. “We are confident that the legislator can answer these small questions satisfactorily, after the Ministry for the Interior and the European Committee for Standardization have positioned themselves,” says Hofmann.

Further information on the topic can be found in the eco white paper Acceptance Factors for E-Invoicing