Germany's Long Road to Peppol: What the Latest Signals Mean

Germany has no Peppol mandate. Its B2B e-invoicing reform requires structured EN 16931 invoices, but it says nothing about how those invoices should travel. In theory, the transport layer is wide open.

In practice, the picture looks different. Over the past year, German public institutions and their closest partners have sent a series of signals that all point towards Peppol. This includes a new Peppol Authority Specific Requirement that would make the Peppol Directory mandatory for German public entities. At the same time, the public invoice receipt platforms of the federal government and the Länder are converging into one, with Peppol as one of its main channels. Lastly, the German e-invoicing forum FeRD has aligned even closer with its French counterpart FNFE, and, as we all know, the French reform is underpinned by Peppol.

Germany has issued no Peppol mandate. Yet the road towards Peppol is being paved, one decision at a time.

No mandate, but Peppol is no stranger

Germany's domestic B2B mandate is format-led, not network-led. Any EN 16931-compliant format qualifies, whether XRechnung or the hybrid ZUGFeRD, and the law does not prescribe a delivery channel. Read our Germany country guide for the full timeline and requirements.

The public sector is a different story. KoSIT became the German Peppol Authority in June 2018, and that same year the IT Planning Council decided that every public authority offering an electronic invoicing service must be reachable via Peppol, as set out in OpenPeppol's Germany profile. Peppol has been the backbone of German B2G invoicing ever since.

What has changed is that the public side is now tightening its grip on Peppol, and the private side increasingly has reasons to follow. Even the German Peppol Authority is now making that case openly. In November 2026, its head, Beate Schulte, co-presents a webinar asking whether Peppol is a must in Germany, framing email-based invoicing as a growing security risk and Peppol as the scalable alternative.

Germany has also given every business a Peppol address. In December 2025, KoSIT registered the German Electronic Business Address (GEBA), a Peppol participant identifier built on the Business Identification Number that the tax authorities assign to every economic operator. Using it is so far voluntary, but an address scheme for the whole German economy, anchored in a tax identifier and designed for Peppol, is exactly the kind of groundwork a future reporting system could build on.

The Peppol Directory would become mandatory for public entities

In November 2026, OpenPeppol's APP CMB approved an updated version of the Peppol Authority Specific Requirements (PASR) for Germany for member review, with comments open until 7 December 2026. The headline change is simple: every German public entity on the Peppol network would have to be published in the Peppol Directory.

The Peppol Directory is the network's human-readable phone book. Each participant gets a Business Card with its name, country and, ideally, contact details, so that trading partners can find it and see which documents it can receive. Under the proposed German requirement, publication would be mandatory and there would be no opt-out. The bar for compliance is deliberately low: a minimal Business Card needs only the organisation's name and country, with the same contact details a German business already publishes in its website imprint (Impressum) recommended on top. Service providers would carry the obligation on behalf of their customers, with a phase-in of six months and a three-month tolerance window after that for genuine backlog.

This matters because Germany has had a discovery problem. Until now, KoSIT's own Peppol FAQ told suppliers that there is no central directory of German public addresses and that addressing concepts differ between the federal, state and municipal levels. Germany could have solved that with a national register. It chose to solve it inside Peppol instead.

The scale of the problem is easy to underestimate. Germany has one federal level, sixteen Länder and around 10,000 municipalities. As a service provider, we hear how hard it can be to find the right address, and how rarely German public entities appear in the Directory compared with the rest of the network. Years of voluntary harmonisation have not fixed that. A mandate may be the only lever left that will.

The revised PASR also reaches beyond the public sector and beyond invoicing. It would require every Peppol document exchange for end users based in Germany to use the Message Level Status setting "ALWAYS_SEND", so that a positive or negative status is returned for each business document, from the date OpenPeppol makes Message Level Status mandatory network-wide. It also extends the German requirements to the pre-award domain, covering procurement before a contract is awarded. KoSIT's migration plan goes further still, encouraging service providers to publish Business Cards voluntarily for all German end users, not just public bodies. Broad Directory coverage across the German market, the plan argues, is a key enabler for reliable addressing.

Germany could have built its own address register. Instead, it chose the Peppol Directory.

One front door for the public sector

Germany has long run a patchwork of invoice receipt platforms. Five Länder use the federal OZG-RE, while Baden-Württemberg, Saarland, Rhineland-Palatinate, North Rhine-Westphalia, Lower Saxony, Hamburg, Bremen and Schleswig-Holstein have run their own portals. That patchwork is now being folded into one.

The first step came on 19 September 2025, when the federal ZRE platform was merged into OZG-RE, leaving the entire federal administration on a single receipt platform with Peppol as one of its main channels. In March 2026, the IT Planning Council went further and backed a single joint platform for the federation and the Länder, with an implementation plan covering governance, financing and migration due in November 2026. The NRW platform has since been selected for the role: one entry point, common standards and three channels, one of them Peppol.

Put the first two signals side by side and the logic becomes clear. One public receiving platform, connected to Peppol, combined with a mandatory Peppol Directory, gives German public buyers a single, discoverable entry point on the network. For a supplier, that is a strong argument for sending through Peppol rather than through portals or email.

In our view, the timing matters as much as the decision. Building one platform for the federation and sixteen Länder forces the public sector to set up new structures, responsibilities and a common addressing concept, all at once. Priorities set during a migration tend to stick. If Peppol visibility is built into those structures now, it becomes the default for years. If it is left for later, it is unlikely to be retrofitted. That is why we see the Directory requirement and the platform consolidation as two halves of the same move.

A migration is the moment to set defaults. Germany's public sector is migrating now.

The Franco-German connection

In September 2026, the French e-invoicing forum FNFE unveiled a new visual identity designed to mirror that of its German counterpart, FeRD. The two organisations have worked together for more than a decade and jointly created the Factur-X / ZUGFeRD standard. When announcing the new identity, FNFE was explicit about the message: the two forums intend to act together at the European level, working towards common standards and genuine cross-border interoperability in line with ViDA. Until now, the partnership has been about formats. But cross-border interoperability is not only a format question. An invoice also has to find its recipient and reach it securely, and that is a transport question. Read that way, the next step of the Franco-German collaboration could well extend from the invoice itself to the network that carries it.

France, for its part, has already chosen Peppol. In practice, Peppol is the interoperability network that connects France's Plateformes Agréées, even though French law does not mandate it as such. Read our France country guide for how that model works.

This is the pattern worth noticing. France did not issue a Peppol mandate either. It built its reform on Peppol and let the network become the default. When Germany's closest e-invoicing partner aligns ever more tightly with a Peppol-based ecosystem, the pull on the German side grows accordingly.

The 2030 question

The biggest open decision still lies ahead. Germany's e-invoicing mandate was always meant as a first step towards a transaction-based reporting system. At a Verband elektronische Rechnung (VeR) event in Berlin, Parliamentary State Secretary Michael Schrodi set out the timetable: the legislative process starts in 2027, a voluntary pilot opens in early 2029, and the system becomes mandatory on 1 July 2030, the same date ViDA's digital reporting requirements apply to intra-EU transactions.

The exchange protocol has not been decided. But the industry has made its preference clear. VeR's strategy paper from May 2026 recommends that the reporting system build on existing infrastructure, EN 16931 and established networks such as Peppol, rather than a new government platform. It describes how a five-corner model could add the tax authority to the existing Peppol flow, much as France has done.

If that is the direction, the signals described above are not coincidences. A mandatory Directory, a single public receiving platform and a Franco-German alliance anchored in a Peppol-based France are exactly the groundwork a five-corner model would need.

What this means for software vendors and service providers

None of this makes Peppol legally mandatory for German B2B invoicing today. But it changes the cost of staying off the network.

• Public sector suppliers will find every German public buyer discoverable in one place, with one receiving platform behind it. Peppol becomes the path of least resistance.
• Service providers serving German public entities would need to make sure their SMP publishes Business Cards and triggers the Directory indexer before the phase-in ends.
• ERP and invoicing vendors that treat Germany as an email-and-ZUGFeRD market risk a second rebuild when the 2030 reporting system arrives. Building Peppol into the German roadmap now avoids that.

Building on Peppol in Germany

At Arratech, we operate at the core of the Peppol network as a certified Access Point and Service Metadata Publisher, with infrastructure pre-accredited across multiple jurisdictions, including France. Our Access Point and SMP services let software vendors and platforms connect once and expand into new markets without building the network layer themselves.

Germany has not announced the destination. But the road it is currently on leads to Peppol.

Talk to Arratech about getting ready for Peppol in Germany.

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