XRechnung and ZUGFeRD: what Germany’s e-invoicing rules mean for you

Since 1 January 2025, every business in Germany must be able to receive e-invoices. Issuing them becomes mandatory in two steps, in 2027 and 2028. Here is what counts as an e-invoice, how XRechnung and ZUGFeRD differ, what the Federal Ministry of Finance says about email, and how to create a valid file.

Last checked 28 October 2026.

The timeline in Germany

The rules cover invoices between businesses established in Germany (domestic B2B). Invoices to private consumers are not covered.

  • Since 1 January 2025: every business must be able to receive e-invoices. There is no transition period for receiving.
  • 2025 and 2026: you may still issue paper invoices. Other electronic invoices, such as a plain PDF by email, need the customer’s consent.
  • From 1 January 2027: businesses whose total turnover in the previous year was above €800,000 must issue e-invoices. Businesses at or below that amount may keep issuing other invoices until the end of 2027.
  • From 1 January 2028: all businesses must issue e-invoices to other businesses in Germany.

Some invoices are exempt from the obligation to issue: small-value invoices with a total of up to €250, travel tickets, and invoices from small businesses using the Kleinunternehmer scheme under § 19 UStG. Small businesses must still be able to receive e-invoices. Certain VAT-exempt supplies are also excluded.

This is general information, not legal or tax advice. Check your own situation with your tax adviser.

What counts as an e-invoice

An e-invoice is an invoice issued, sent and received in a structured electronic format that software can process and that follows the European standard EN 16931. A PDF on its own is no longer an e-invoice, even when it is sent by email. It counts as an “other invoice”.

Formats that meet the rules include XRechnung, ZUGFeRD from version 2.0.1 and other formats that follow EN 16931. For ZUGFeRD, the MINIMUM and BASIC WL profiles are not enough, because they do not carry a full invoice.

ZUGFeRD is a hybrid format: a PDF with the invoice data attached as XML. The Federal Ministry of Finance’s letter of 15 October 2024 says the XML data is what counts. If the PDF and the XML differ, the XML wins.

Sending by email: what the BMF letter says

The Federal Ministry of Finance (BMF) explained the rules in a letter dated 15 October 2024. The law does not prescribe how an e-invoice must travel, and the letter names several possible routes. Sending the e-invoice file by email is one of the permitted electronic routes; others include download from a portal and interfaces between systems.

For receiving, the letter says it is enough for the recipient to provide an email inbox (paragraph 40). Businesses can agree on other routes between themselves.

So in Germany you can email your customer a ZUGFeRD PDF or an XRechnung file. What matters is the file, not the channel: the structured data must be attached, and a plain PDF does not qualify once the transition rules end for you.

Later BMF letters of 15 October 2025, mainly on format requirements and validation, and of 15 October 2026, with further rules for example on advance and partial invoices, add detail to these rules.

XRechnung or ZUGFeRD: which one?

XRechnung is the German version of EN 16931, maintained by the Coordination Office for IT Standards (KoSIT). It is a pure XML file, so people need a viewer to read it. Invoices to federal authorities must meet the XRechnung standard, and many other public bodies ask for it too. Public bodies identify themselves with a Leitweg-ID, which you put on the invoice.

ZUGFeRD is a PDF that people can read, with the same kind of XML data inside. It is technically the same standard as France’s Factur-X. The EN 16931 profile (also called COMFORT) carries the full invoice data.

  • Business customers: a ZUGFeRD PDF suits most of them, because the accounts team can read it and their software can import it.
  • Customers who ask for XRechnung, and all public bodies: send XRechnung, with the Leitweg-ID for public bodies.
  • Not sure: ask the customer. Many will accept both.

What XRechnung needs that other formats do not

XRechnung adds some rules on top of EN 16931. The most common gaps on small-business invoices are:

  • A contact person for the seller with name, phone number and email address.
  • The town and postcode of both seller and buyer.
  • An electronic address for both sides: a Peppol ID or an email address.
  • A buyer reference. For public bodies this must be the Leitweg-ID. For businesses, the purchase order number or a similar reference is common.

How to create an XRechnung or ZUGFeRD invoice with our tool

  1. In our e-invoice generator, open Your invoice details and fill in your legal name, address, VAT ID or tax number, and the contact name, phone and email. Choose Save details.
  2. Choose New invoice. Enter the customer’s name, address with postcode and town, country and email address.
  3. For a public body, enter the Leitweg-ID in Customer’s reference. For a business, enter their purchase order number there if they gave you one.
  4. Add the lines with VAT type Standard VAT and VAT % 19 or 7, or another VAT type if it applies.
  5. Choose Check and issue and fix anything the list at the top asks for.
  6. Download PDF with e-invoice inside (Factur-X / ZUGFeRD) or XRechnung, or email them from your own mailbox with Send invoice.

The XRechnung file follows XRechnung 3.0 in UBL syntax. The PDF contains the invoice data in the EN 16931 profile.

Coming next: XRechnung 4.0

A revised edition of the European standard, EN 16931-1:2026, was published in 2026. KoSIT released a preview of XRechnung 4.0, based on it, in September 2026, and expects the final version in spring 2027. According to current plans, the old and new editions of the standard can be used side by side until March 2029. Our tool creates XRechnung 3.0, the version in use today.

Questions

Can I still send PDF invoices to German business customers?

In 2025 and 2026, yes, if the customer agrees; paper is also still allowed. In 2027, only if your total turnover in 2026 was €800,000 or less, again with the customer’s agreement. From 2028 invoices to other businesses in Germany must be e-invoices, unless an exemption applies, such as invoices up to €250. A ZUGFeRD PDF with the XML inside counts as an e-invoice.

Is an email inbox enough to receive e-invoices?

Yes. The BMF letter of 15 October 2024 says that providing an email inbox is enough to receive e-invoices. You still need a way to read XRechnung files, which are pure XML. Many accounting programs and free viewers can display them, and a ZUGFeRD PDF opens in any PDF reader.

I use the Kleinunternehmer scheme. Do I have to issue e-invoices?

No. Invoices from small businesses using § 19 UStG are exempt from the obligation to issue e-invoices. You must still be able to receive them, which an email inbox covers. You may still choose to send e-invoices, for example when a customer or public body asks for them.

What is a Leitweg-ID?

It is the routing ID of a German public body, which tells the authority’s invoice system where your invoice belongs. The public body gives it to you, usually with the order. Put it in the buyer reference of the XRechnung. In our tool that is the field Customer’s reference.

Does the rule apply to sellers outside Germany?

The obligation covers supplies between businesses established in Germany. If your business is elsewhere, your German customer may still prefer an e-invoice, because their software processes it automatically. Ask them which format they want. This is general information, not legal advice.

Sources

General information, not legal advice. Laws and dates change; check the sources or ask an adviser for your situation.