Is Peppol Mandatory in Germany? B2B, Public Sector and Costs

No, Peppol is not mandatory in Germany. Since 1 January 2025, Section 14 of the German VAT Act (§ 14 UStG) has set the format of a domestic B2B e-invoice, not the channel. Businesses agree on the channel themselves, and e-mail is enough. Federal authorities also accept e-mail, upload and web entry besides Peppol. Peppol pays off mainly at high invoice volumes.

This guide is for finance teams, foreign suppliers and founders who are asked about "Peppol" by a German customer or a software vendor. It explains what Peppol is, when you need it, how the connection works and what it costs, with the official German sources for each point.

What is Peppol?

Peppol is an international network with common specifications that lets businesses and public bodies exchange documents such as e-invoices in a standard way, directly between their systems. The name originally stood for "Pan-European Public Procurement Online".

According to the FAQ of the federal e-invoicing website (opens in a new tab) (E-Rechnung des Bundes), the network is run by OpenPeppol AISBL, a non-profit organisation based in Brussels. OpenPeppol provides the transport network (Peppol eDelivery Network) and the document specifications (Peppol Business Interoperability Specifications, BIS). In Germany, the Coordination Office for IT Standards (Koordinierungsstelle für IT-Standards, KoSIT) acts as Peppol Authority on behalf of the IT Planning Council. For a short definition, see what Peppol is in our glossary.

The key point for the mandate question: Peppol is mainly a transport route. XRechnung is a data format. An XRechnung can travel over Peppol, but it can travel by e-mail just as well.

Is there a Germany Peppol mandate?

No, neither for B2B nor for invoices to federal authorities. The details depend on who you invoice.

B2B: the parties choose the channel

§ 14(1) UStG (opens in a new tab) defines an e-invoice by its format: it is "issued, transmitted and received in a structured electronic format" that complies with EN 16931 (or an agreed format that is interoperable with it). The law names no transport network.

The German Federal Ministry of Finance (BMF) is more explicit in its letter of 15 October 2024 (opens in a new tab) (BStBl I p. 1320):

• Para. 36: The parties agree on the format and the transmission channel under civil law. The BMF lists e-mail, an electronic interface, a shared storage location within a group, and download from an internet portal as examples.
• Para. 40: An e-mail inbox is enough to receive e-invoices, and it may be an existing one.
• Para. 26: Besides XRechnung and ZUGFeRD, other EN 16931 formats are allowed, and the BMF names "Peppol-BIS Billing" explicitly.

So Peppol appears in the BMF letter as an allowed format, not as a required channel. The issuing deadlines and the EUR 800,000 rule for 2027 are covered in Germany e-invoicing 2027.

Foreign suppliers

The domestic B2B obligation in § 14(2) no. 1 UStG applies only when both the supplier and the customer are established in Germany. If you invoice a German business from abroad, you and your customer agree on format and channel. If you already use Peppol in your home market, ask whether your German customer can receive via Peppol before you assume it.

Federal authorities: Peppol as one option at the OZG-RE

Invoices to the German federal administration go through the federal invoice platform OZG-RE. According to the federal page on the Peppol channel (opens in a new tab), suppliers can choose between four channels: Peppol, e-mail, upload and manual web entry. Peppol is the only one that allows machine-to-machine communication and bulk sending. It is not mandatory. Registration on the OZG-RE is required for every channel and is free for suppliers. The full process is in our guide to the Germany e-invoice portal.

How does the Peppol network in Germany work?

The federal FAQ describes the transport as a four-corner model:

Two directories make sure corner 2 finds the right receiver:

1. SML (Service Metadata Locator): there is one for the whole network, operated centrally by OpenPeppol. When a receiver is registered, it creates a DNS entry.
2. SMP (Service Metadata Publisher): it holds the receiver's Peppol ID, the document types the receiver accepts, and the Access Point it uses.

The sender's Access Point looks up the receiver's SMP from the Peppol ID, checks that the receiver accepts the document, and delivers it to the receiver's Access Point. Access Points use the AS4 profile.

Peppol ID, Leitweg-ID and BT-10

In the network you address a participant with a Peppol Participant ID: a four-digit prefix plus an identifier.

According to the federal FAQ, these IDs are not applied for; they derive from an identifier you already have. Receivers must be registered in an SMP so that senders can find them. If you only send, you do not need an SMP entry. Your service provider can handle the registration for you.

A common mistake concerns envelope versus invoice. The Peppol receiver ID goes into the technical envelope, the Standard Business Document (SBD). Inside the XRechnung, the buyer reference (Leitweg-ID, BT-10) must contain the Leitweg-ID without the prefix. If it is missing there, the OZG-RE rejects the invoice. The invoice itself does not change for Peppol. For authorities outside the OZG-RE, the Peppol ID and the Leitweg-ID may differ, so ask the buyer. How the buyer reference works in B2B is explained in Leitweg-ID for companies.

Service provider or own Access Point?

The federal website describes two ways to connect:

The federal recommendation depends on volume: build your own Access Point only if your annual invoice volume justifies it; otherwise use a provider. OpenPeppol publishes a list of certified Access Points.

Whichever route you choose, you stay responsible for the content. The BMF allows external service providers, but the supplier must ensure that the requirements of §§ 14 and 14a UStG are met (BMF letter of 15 October 2024, para. 37).

When is Peppol worth it?

A Peppol connection makes sense if at least one of these applies:

1. You send many invoices to authorities or large customers and want to send them straight from your ERP.
2. A customer requires Peppol in the contract or in its supplier portal.
3. You also invoice in countries where Peppol is common for public or B2B invoicing and want one channel for all.
4. Your invoicing software already offers Peppol, so no separate project is needed.

If none applies, e-mailing the XRechnung or ZUGFeRD file is enough. For occasional invoices to federal bodies, the OZG-RE upload or web entry is free. All channels are compared in how to send e-invoices in Germany, and the trade-offs are summarised in Peppol vs direct sending.

Outlook: the reporting system

In para. 41 the BMF states that e-invoicing platforms will matter for the data exchange in a reporting system that is to be introduced by law at a later date, and that the permitted channels will have to be redefined for it. No such law exists yet. Whether Peppol will play a role is open.

How to prepare a Peppol invoice with docutools.pro

docutools.pro does not send invoices over Peppol. Its tools help you check the file before you hand it to your provider or the OZG-RE.

1. Check the Leitweg-ID. Enter the buyer's ID in the Leitweg-ID validator on the "Validate" tab. It checks structure and check digit in your browser, not whether the ID is registered. Then build the Peppol receiver ID as 0204: plus the checked ID.
2. Create the XRechnung. In the XRechnung generator, enter the Leitweg-ID under "Company" in the "Buyer reference / Leitweg-ID" field (BT-10), then choose "XRechnung XML" under "Export". Pass the file to your Peppol provider or upload it to the OZG-RE.
3. Validate before sending. Load the XML into the XRechnung validator. The file is sent to our server for the check, which works the way the KoSIT validator does (configuration 2026-08-31). The result "KoSIT-conformant / Valid XRechnung" shows that the schema and XRechnung rules such as BR-DE-15 are met. The free plan allows 2 uploads per day up to 500 KB; the Pro plan has no daily upload limit.

The viewer checks XRechnung and plain EN 16931 files. A file with a Peppol BIS identifier in BT-24 does not match any of its validation scenarios. More guides on portals, fields and versions are in our XRechnung guides.

Sources

• E-Rechnung des Bundes: Peppol transmission channel (German) (opens in a new tab)
• E-Rechnung des Bundes: FAQ, Peppol section (German) (opens in a new tab)
• BMF letter of 15 October 2024, BStBl I p. 1320, paras. 26, 36, 37, 40, 41 (German, via IHK) (opens in a new tab)
• § 14 UStG (German) (opens in a new tab)

Last reviewed: November 2026

This article is general information, not tax or legal advice.