Electronic Invoice in Public Procurement 2026

Definition: The electronic invoice (e-invoice) in public procurement is an invoice issued, transmitted, and received in a structured electronic format that enables automatic and electronic processing, and which public contracting authorities are required to accept and process under Directive 2014/55/EU.

Last updated: January 2026 · Legal basis: Directive 2014/55/EU, European Standard EN 16931, German E-Invoicing Act (ERechG), E-Invoicing Regulation (ERechV), Austria: ICT Consolidation Act

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What is an electronic invoice in public procurement?

The electronic invoice (e-invoice) is more than just a PDF invoice sent by email – it is a structured, coded invoice that is machine-readable and automatically processable. Directive 2014/55/EU on electronic invoicing in public procurement obliges all public contracting authorities in the EU to receive and process e-invoices that comply with the European Standard EN 16931.

The European Standard EN 16931 defines a uniform semantic data model for invoices that can be expressed in different syntaxes (e.g. UBL 2.1, UN/CEFACT CII). The widespread national formats (ZUGFeRD/Factur-X in Germany and Austria, XRechnung in Germany) must conform to the standard.

Legal situation in Germany

In Germany, the obligation to issue electronic invoices to federal authorities has been fully in force since 27 November 2020. The E-Invoicing Act (ERechG) and the E-Invoicing Regulation (ERechV) transpose Directive 2014/55/EU. Federal authorities are obliged to receive e-invoices in the XRechnung format (or another EN 16931-compliant format). At federal state and municipal level, different transitional rules apply.

From 2025, a general B2B e-invoicing obligation will also apply in the area of VAT in Germany, which is also indirectly relevant for procurement procedures.

Legal situation in Austria

In Austria, invoices to federal authorities have had to be transmitted electronically since 1 January 2014. Austria was thus one of the first countries in the EU with a far-reaching e-invoicing obligation. Invoices to federal authorities must be submitted via the Business Service Portal (USP) in the "ebInterface" format. Different rules may apply to invoices to federal states and municipalities.

Formats and standard

The European Standard EN 16931 is the mandatory basis; nationally, various conforming syntaxes are in use.

Format	Country	Description
XRechnung	Germany	XML-based format for federal authorities
ZUGFeRD / Factur-X	Germany, Austria, France	Hybrid format (PDF + XML)
ebInterface	Austria	Austrian XML format for federal authorities
PEPPOL BIS	EU-wide	Interoperable transmission format via the PEPPOL network

PEPPOL network

The PEPPOL network (Pan-European Public Procurement Online) is the preferred infrastructure for the secure, interoperable transmission of e-invoices in European public procurement. PEPPOL allows invoices to be transmitted across countries and platforms.

Related terms

• E-procurement
• Electronic contract awarding
• Electronic marketplace (EMP)

FAQ

Is a PDF invoice sufficient as an electronic invoice within the meaning of Directive 2014/55/EU? No. A simple PDF invoice is not an e-invoice within the meaning of the Directive because it is not structured and machine-readable. The hybrid format ZUGFeRD/Factur-X, however, contains a machine-readable XML in addition to the readable PDF view and can be recognised as an e-invoice.

Must all suppliers to federal authorities issue e-invoices? In Germany, yes, where public contracts are involved. The obligation to issue electronic invoices applies to contractors of public contracting authorities at federal level.

What software is needed to create XRechnung invoices? There are numerous free and commercial software solutions available. The Bundesdruckerei also offers a free online editor for XRechnung.

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Last updated: January 2026 All information provided without guarantee. For legally binding advice, please consult a law firm specialising in public procurement law.