XRechnung and ZUGFeRD: Germany's e-invoicing timeline

Germany requires structured e-invoices for domestic B2B supplies in three steps: every business must be able to receive them since 1 January 2025, businesses with more than EUR 800,000 prior-year turnover must issue them from 1 January 2027, and everyone else from 1 January 2028. XRechnung and ZUGFeRD are formats, not platforms: there is no central clearance system.

The timeline in three steps

The rules come from the Growth Opportunities Act and are explained in the BMF questions and answers on the e-invoice and in two administrative letters of 15 October 2024 and 15 October 2025. The EUR 800,000 threshold refers to the total turnover of the whole business in the previous calendar year, not only its B2B share.

What counts as an e-invoice

German law follows the European standard EN 16931, introduced for public procurement by Directive 2014/55/EU. An e-invoice is a structured electronic document that software can process automatically. A plain PDF is not an e-invoice; from 2025 the law calls it an "other invoice".

XRechnung is the German national profile of EN 16931, maintained by the KoSIT coordination office. It is pure XML in UBL or CII syntax, built for invoices to public bodies, with fields such as the buyer reference (Leitweg-ID). Opening the file shows XML, not a readable invoice.

ZUGFeRD is a hybrid: a PDF/A-3 file with the XML invoice embedded. People read the PDF; software reads the XML. ZUGFeRD is technically identical to the French Factur-X. According to the BMF, ZUGFeRD from version 2.0.1 qualifies in the BASIC, EN 16931, Extended and XRechnung profiles; MINIMUM and BASIC-WL do not. See the ZUGFeRD and Factur-X glossary entry.

Peppol BIS Billing 3.0 also conforms to EN 16931 and is accepted. Peppol is a delivery network as well as a format, explained in our guide to Peppol for small businesses.

Which format should a small business use?

For most small businesses ZUGFeRD is the practical choice, because it works for customers who still read invoices and for those who process them automatically. XRechnung is the right choice for public bodies, which often require it. If your tax adviser uses DATEV, ask which format they prefer for incoming batches.

Delivery: no central platform

Germany has no clearance system, so delivery is your choice:

• E-mail with the XML or ZUGFeRD file attached. Enough for receiving and, for most small businesses, for issuing.
• Peppol through an access point, for public-sector customers and larger counterparties.
• Portals for public bodies: at federal level this is the OZG-RE, the only federal platform since the ZRE was merged into it in September 2025.
• EDI, which remains possible where the data can be extracted in line with EN 16931.

The tax authority therefore does not see invoices at issue. That will change for intra-EU supplies with the digital reporting under ViDA from July 2030. Germany has not published a date for domestic reporting.

Archive the XML, not the PDF

The structured part of an e-invoice is the legally relevant document. Archiving only the PDF and discarding the XML does not meet the retention rules, which the BMF clarified in its 2025 update of the bookkeeping principles (GoBD). The better step is to route incoming files straight into bookkeeping: supplier, amounts, VAT rate and due date are already in defined fields, so nothing has to be typed.

VAT details to get right

Germany applies 19 % standard VAT and 7 % reduced VAT. A structured invoice needs the correct rate category on each line and the seller's VAT ID (USt-IdNr.) or tax number in the right field. Small businesses under the scheme invoice without VAT and must state why; the format has a dedicated exemption code, so software should use it rather than a zero rate.

How Kontevia fits

Kontevia is in early access. It produces structured invoices following EN 16931, with XRechnung and ZUGFeRD prepared for Germany, reads incoming XML including the XML embedded in ZUGFeRD, and offers Excel and CSV exports today; a DATEV export is planned. See e-invoicing in Kontevia for the current scope.

Official sources

• BMF: questions and answers on the mandatory e-invoice
• BMF letter of 15 October 2025 on the e-invoice
• KoSIT: XRechnung standard
• Directive 2014/55/EU on EUR-Lex

This article is general information and does not replace advice from a tax adviser. Information valid as of 11 October 2026.

Frequently asked questions

When do German businesses have to issue e-invoices?

Businesses with total turnover above EUR 800,000 in the previous year must issue e-invoices for domestic B2B supplies from 1 January 2027. All others follow from 1 January 2028. Receiving has been mandatory for every business since 1 January 2025.

Is a ZUGFeRD invoice a valid e-invoice in Germany?

Yes, from ZUGFeRD version 2.0.1 onwards, in any profile except MINIMUM and BASIC-WL. BASIC, EN 16931 (Comfort), Extended and XRechnung qualify; MINIMUM and BASIC-WL are not e-invoices in the legal sense.

Do small businesses and small invoices have to be e-invoices?

Invoices up to EUR 250 gross (Kleinbetragsrechnungen) and invoices from businesses under the small business scheme (Kleinunternehmer) are exempt from the issuing obligation. Every business must still be able to receive e-invoices.

Does the German mandate apply to foreign suppliers?

The obligation covers domestic B2B supplies between businesses established in Germany. A supplier without an establishment in Germany is generally outside it, although German customers increasingly ask for structured invoices anyway.

Topics:XRechnungZUGFeRDGermanye-invoicingE-RechnungspflichtEN 16931

Kontevia is in early access. Country-specific behaviour described here reflects the rules of each state, not a promise that every feature is live in your country today.