Mandatory e-invoicing: ZUGFeRD or XRechnung?
Both formats meet the legal requirements — but for different recipients. A comparison.
The e-invoicing mandate from 2025
Since January 1, 2025, all VAT-liable companies in Germany must be able to receive e-invoices. Mandatory sending is being phased in: from 2027 for companies with more than €800,000 in annual turnover (prior year), and from 2028 for all others — under § 14 of the German VAT Act (UStG).
Two formats, one goal
Two structured formats have become established in Germany: XRechnung as a pure XML format and ZUGFeRD as a hybrid of a human-readable PDF and embedded XML. Both formats meet the legal requirement for a structured e-invoice under EN 16931.
XRechnung: the public sector format
XRechnung was developed for public procurement and has been mandatory for B2G (business-to-government) invoices to German federal authorities since 2020. The format consists exclusively of machine-readable XML — it offers no visual representation. Recipients need special software to display it.
ZUGFeRD: the B2B standard
ZUGFeRD combines the familiar PDF invoice layout with an embedded XML data set under EN 16931. The recipient sees the familiar invoice while their accounting system processes the XML data automatically. This makes ZUGFeRD particularly popular in the B2B sector.
- ZUGFeRD 2.3 profile COMFORT is considered the minimum level for legally compliant e-invoices
- XRechnung 3.0 is the standard for German federal authorities and many state authorities
- Both are based on the EU standard EN 16931 and are mutually compatible
- Plain PDF invoices by email no longer meet the legal requirement from the statutory deadlines onward
What you specifically need to do now
Check whether your accounting system can generate and import e-invoices in the ZUGFeRD or XRechnung format. Many software products already support this natively. For existing PDF workflows, converter services such as taxlayer.de enable conversion into standards-compliant e-invoices without changing systems.
Frequently asked questions
Do all companies have to send e-invoices immediately?
No, mandatory sending is being phased in. Companies have already had to be able to receive e-invoices since January 1, 2025. For mandatory sending: from 2027 for companies with more than €800,000 in turnover (prior year), from 2028 for all remaining domestic B2B invoices.
Does the e-invoicing mandate also apply to small businesses under § 19 UStG?
Small businesses are largely exempt from the sending obligation but must be able to receive e-invoices. Partially different rules apply to B2G invoices (to public authorities). Switching to e-invoices voluntarily can still make sense.
Can I still send PDF invoices by email?
From the statutory deadlines onward, a plain PDF file by email no longer counts as an e-invoice within the meaning of § 14 UStG unless it contains an embedded XML data set. ZUGFeRD is a PDF file with integrated XML — and therefore fully compliant.
Does my business partner have to accept the ZUGFeRD format?
Yes. The statutory obligation to receive means your business partner must accept e-invoices under EN 16931 (i.e., ZUGFeRD COMFORT and higher as well as XRechnung). They cannot demand a plain PDF invoice. Clarify with customers which format their system prefers.