XRechnung vs ZUGFeRD: Germany's E-Invoice Rules

Quick answer: XRechnung is Germany's XML e-invoice format based on EN 16931; ZUGFeRD is a hybrid PDF with embedded XML that also counts as an e-invoice if it uses a compliant profile. Since 1 January 2025 every German business must be able to receive e-invoices. Issuing becomes mandatory from 1 January 2027 for businesses with prior-year turnover above €800,000, and for all businesses from 1 January 2028.

If a German customer has asked you for an XRechnung, or your accountant has warned you about the "E-Rechnungspflicht", this guide is for you. It explains the timeline, the difference between XRechnung and ZUGFeRD, which invoices are exempt, and what small businesses and foreign suppliers need to do. Until the mandate catches up with you, a PDF from our free invoice generator still works; after that, you will need software that outputs a compliant format.

Important: This is general information, not tax or legal advice. The rules come from the Growth Opportunities Act (Wachstumschancengesetz) and guidance letters from the Federal Ministry of Finance (BMF), which are updated from time to time. Check the latest BMF e-invoice FAQ or ask a Steuerberater before relying on any detail here.

Germany's e-invoicing timeline

Date	What applies
1 January 2025	All domestic businesses must be able to receive e-invoices. No transition period for receiving.
1 January 2025 to 31 December 2026	Issuing: paper and other electronic invoices (such as PDF) still allowed for domestic B2B, PDF with the buyer's consent.
1 January 2027	Businesses with prior-year (2026) total turnover above €800,000 must issue e-invoices for domestic B2B sales.
1 January 2027 to 31 December 2027	Businesses with 2026 turnover up to €800,000 may still issue paper and other electronic invoices. EDI invoices agreed between parties remain possible during this period.
1 January 2028	All domestic businesses must issue e-invoices for domestic B2B sales.

The €800,000 test uses your total turnover for the previous year, not just your B2B sales. A business that sells mostly to consumers but crosses €800,000 in 2026 still has to issue e-invoices for its B2B sales from 2027.

What counts as an e-invoice in Germany?

Since 2025, German VAT law defines an e-invoice (E-Rechnung) as an invoice issued, transmitted and received in a structured electronic format that allows electronic processing and complies with the European standard EN 16931 (or another format agreed between the parties, as long as the required data can be correctly extracted into an EN 16931-compliant format).

Everything else is an "other electronic invoice" (sonstige Rechnung), including:

• A PDF sent by email, whatever software created it
• A scanned paper invoice
• An image or Word file

That distinction is the heart of the rules. Our wider e-invoicing guide explains why most countries draw the same line.

XRechnung vs ZUGFeRD vs Factur-X

	XRechnung	ZUGFeRD (2.x)	Factur-X
What it is	German CIUS (national specification) of EN 16931	Hybrid: PDF/A-3 with embedded CII XML	French name for the same hybrid format (technically identical to ZUGFeRD 2.x)
Human-readable?	No, XML only (needs a viewer)	Yes, PDF part	Yes, PDF part
Syntax	UBL or CII	CII	CII
Valid German e-invoice?	Yes	Yes, with EN 16931, EXTENDED or XRECHNUNG profile	Yes, with an equivalent profile
Typical use	Public sector (B2G), and B2B	B2B, especially small businesses	B2B in France and Germany

For the hybrid formats, the XML is the legally binding part. If the PDF view and the XML disagree, the XML wins, so make sure your software generates both from the same data. Profiles MINIMUM and BASIC WL are not e-invoices under German law because they lack line-level detail.

Which should you choose?

• Selling to German public authorities: use XRechnung (or a format the authority accepts) and include the buyer's Leitweg-ID. Federal authorities accept submission via their portals or Peppol.
• Selling B2B to small firms: ZUGFeRD is often easier for the recipient, who can open the PDF even without e-invoice software.
• Selling B2B to larger firms: ask. Many prefer XRechnung or Peppol BIS Billing, which drop straight into their systems. See what Peppol is for how that network works.

Which invoices are exempt?

• B2C sales to private consumers
• Small-amount invoices (Kleinbetragsrechnungen) with a gross total up to €250
• Passenger transport tickets
• Kleinunternehmer (small business scheme) are exempt from issuing e-invoices, though they must be able to receive them
• Certain VAT-exempt supplies, such as many medical or financial services, under the specific rules in the BMF guidance
• Cross-border sales: the mandate covers domestic B2B supplies between businesses established in Germany. Intra-EU and export sales are not yet in scope.

What must a German e-invoice contain?

The normal German invoice requirements in section 14 of the VAT Act still apply, now as data fields: supplier and customer full names and addresses, supplier's tax number (Steuernummer) or VAT ID (USt-IdNr.), issue date, sequential invoice number, quantity and description of goods or services, date of supply, net amount broken down by tax rate, applicable rate, tax amount, and any notes on exemptions or reverse charge. If any line is reverse charged, use the wording in our reverse charge invoice guide. For an overview of VAT IDs compared with other countries' tax numbers, see tax ID on an invoice.

Worked example: does the 2027 deadline apply to you?

A Munich carpentry business made these sales in 2026:

Sales in 2026	Net turnover (€)
Kitchens fitted for private households (B2C)	520,000
Shopfitting for retailers (domestic B2B)	265,000
Joinery for a building contractor in Austria (cross-border B2B)	40,000
Total turnover	825,000

The maths: 520,000 + 265,000 + 40,000 = €825,000, which is above €800,000. From 1 January 2027 every invoice for its domestic shopfitting work must be an e-invoice, even though B2B is less than a third of sales. Its household kitchens can still be invoiced on paper or PDF, and the Austrian contractor's invoices are outside the German domestic mandate. Had total turnover been €790,000, the business could have kept issuing PDFs for B2B until the end of 2027.

Foreign suppliers selling to Germany

The German mandate applies to domestic B2B supplies between businesses established in Germany. If you are a freelancer or company abroad with no German establishment, you are generally not obliged to issue XRechnung or ZUGFeRD to German clients, and a clear PDF remains acceptable under the law. That is the legal position; the commercial one can differ. Larger German buyers are rebuilding their accounts payable around structured invoices, and some now ask every supplier, foreign or not, to send XRechnung, ZUGFeRD or a Peppol invoice, or to upload to a supplier portal. If a client asks, treat it as a contract question rather than a tax one and agree the format in writing.

Foreign businesses that are VAT-registered in Germany because they have a fixed establishment there are in a different position, so check with a Steuerberater if that applies to you. For cross-border invoices, reverse charge wording and VAT IDs matter more than the format; our guide to invoicing international clients covers both.

Common mistakes with German e-invoices

• Sending a ZUGFeRD file with the wrong profile. MINIMUM or BASIC WL files look like e-invoices but do not meet the legal definition.
• Archiving only the PDF view. The XML is the original document and must be kept unaltered.
• Treating the PDF and XML as separate documents. If they differ, the XML wins, so your software must generate both from one dataset.
• Forgetting the Leitweg-ID on invoices to public authorities, which causes automatic rejection.

How to receive e-invoices (already required)

Receiving is the obligation most small businesses overlooked in 2025. The BMF has said that providing an email inbox is enough to "be able to receive". In practice you also need a way to read the XML:

• Accounting software or online tax tools that import XRechnung and ZUGFeRD
• A free viewer for occasional XML files (several public-sector and open-source viewers exist)
• An archive that keeps the original XML file, not only a printout, for the full retention period (generally eight or ten years depending on the record). See how long to keep invoices.

Can I make an XRechnung with a free invoice generator?

Not with ours. Our generator is free, runs in your browser, saves drafts in local storage and exports a standard PDF. It does not create XRechnung XML or embed ZUGFeRD data, so its PDFs count as "other electronic invoices" in Germany. That is fine for B2C, small-amount invoices, Kleinunternehmer, foreign clients, and domestic B2B during the transition periods above. Once the mandate applies to you, use accounting software that outputs XRechnung or ZUGFeRD.

For PDF invoices in the meantime, the Nordic template gives the VAT ID and tax-rate breakdown a clean layout, and you can compare other designs in our invoice templates gallery.

Next step

Check your 2026 turnover now. If it is above €800,000, pick software that issues XRechnung or ZUGFeRD before January. If it is below, you have until 2028, but make sure you can already receive and archive e-invoices. If you also sell into France, our guide to the France e-invoicing reform explains how Factur-X fits there.