Choosing a format
XRechnung or ZUGFeRD: two questions, not one
Both are EN 16931 e-invoices with the same content. The question “XRechnung or ZUGFeRD” mixes two decisions: which rule set the invoice meets, and whether it travels as plain XML or as a PDF with the XML inside. Separate the two and you know in two steps what your recipient needs — shown here with the same invoice in both formats to download.
The short answer
- To a public authority: XRechnung, as a plain XML file. The federal invoice platform, OZG-RE, accepts ZUGFeRD only in the XRECHNUNG profile, and even then only the XML without the PDF.
- To a business: both are valid e-invoices. ZUGFeRD in the EN 16931 profile is usually easier, because the recipient can read the PDF without any software. Which format applies is for you and your customer to agree.
- Not an e-invoice: ZUGFeRD in the MINIMUM and BASIC WL profiles, and a PDF without XML inside.
Rule set and container
XRechnung is first of all a rule set: the German usage specification of the EN 16931 standard, run by KoSIT. It makes mandatory what the standard leaves open — the buyer reference, which for authorities is the Leitweg-ID, electronic addresses, and a contact at the seller. ZUGFeRD is first of all a container: a PDF/A-3 with the invoice data inside as XML. Which rules that XML meets is what the profile says.
| Plain XML | PDF with XML (ZUGFeRD) | |
|---|---|---|
| XRechnung rules | XRechnung in UBL or CII. The standard for authorities. | ZUGFeRD in the XRECHNUNG profile: an XRechnung in CII, inside the PDF as xrechnung.xml. |
| EN 16931 only | XML under the standard, without the German additions. Valid between businesses. | ZUGFeRD in the EN 16931 profile (formerly Comfort), inside the PDF as factur-x.xml. The usual ZUGFeRD between businesses. |
In all four cells the XML is the same data model; only the XRechnung row also meets the German rules. That is why a generator turns the same details into any of the four files, and why an XRechnung to a business is not wrong, only stricter than needed. What is inside a ZUGFeRD PDF is on the page The ZUGFeRD format; which ZUGFeRD profile for what, on ZUGFeRD Extended or XRechnung.
The same invoice, every format
Two cases from our sample library, each as UBL, as CII and as a ZUGFeRD PDF. Every file passed the KoSIT validator on 22 October 2026 (rule set v2026-08-31). Open the XML in an editor and the PDF in a reader: the amounts, lines and parties are the same.
| File | Case 01 · as an XRechnung | Case 36 · EN 16931 to a business |
|---|---|---|
| XML in UBL | Download · 5 KB | Download · 5 KB |
| XML in CII | Download · 8 KB | Download · 8 KB |
| ZUGFeRD PDF | Download · 43 KB | Download · 41 KB |
What differs between the columns is the specification identifier (BT-24) at the top of each XML: urn:cen.eu:en16931:2017#compliant#urn:xeinkauf.de:kosit:xrechnung_3.0 for the XRechnung, urn:cen.eu:en16931:2017 for the invoice under the standard alone. The PDFs are several times the size of the XML they carry; the fonts and the page image make the difference.
Both cases with their description and the request they are made from: case 01 and case 36 in the e-invoice examples.
What the recipient needs
Federal authorities
XRechnung in UBL or CII, through OZG-RE. It accepts ZUGFeRD only in the XRECHNUNG profile and only as a purely structured XML file without the visual part — without the PDF, that is, which leaves nothing of the ZUGFeRD but an XRechnung in CII. The buyer reference has to be the authority’s Leitweg-ID. How registration and submission work: invoicing federal authorities.
States and municipalities
Also XRechnung, through the state’s portal or Peppol; five states share the federal OZG-RE. Whether a state portal also accepts ZUGFeRD is up to each state — the authority names the portal and the Leitweg-ID with the order.
Businesses
Any EN 16931 e-invoice satisfies the VAT Act, as XML or as ZUGFeRD. Which format you send is, according to the Federal Ministry of Finance, a civil-law question for the contracting parties alone. Without an agreement, ZUGFeRD in the EN 16931 profile is the choice least likely to go wrong: the accounting software reads the XML, the person reads the PDF. You do not need the recipient’s consent to send an e-invoice.
Consumers
No e-invoice required. An ordinary PDF or paper is enough; a ZUGFeRD PDF does no harm, as it opens like any PDF.
With ZUGFeRD, the XML is what counts
A ZUGFeRD PDF holds the invoice twice: as a page for people and as XML for software. The Ministry of Finance has settled which one applies — the XML is the leading part, and where the two differ its data prevails over the image. Input tax can be deducted only from the structured part; an image part with different details can count as a second invoice, with the tax it shows.
Anyone assembling ZUGFeRD from two sources — the PDF from Word and the XML from a form, say — therefore has to make sure both say the same. Our ZUGFeRD Viewer shows the embedded XML beside the PDF, so you can compare them.
The current versions
| Format | In force | Next |
|---|---|---|
| XRechnung 3.0 | since 1 February 2024, until at least 31 July 2027; current bundle 3.0.2 | XRechnung 4.0: pre-release since September 2026, final version expected in spring 2027 |
| ZUGFeRD 2.5.2 = Factur-X 1.09.2 | published 4 August 2026, applicable since 1 September 2026 | Next release with gross-price invoices, announced by FeRD for autumn 2026 |
Both build on the 2017 edition of EN 16931, even after a new edition appeared in 2026. What the standard lays down: The EN 16931 standard.
Common questions
Is ZUGFeRD an XRechnung?
Only in the XRECHNUNG profile: then the PDF contains a complete XRechnung in CII. In the usual EN 16931 profile the XML meets the standard but not the German additions, and so is not an XRechnung.
Does my customer have to accept ZUGFeRD if they want XRechnung?
Tax law does not decide it; the format is a matter for your contract. All that is settled is this: a recipient who refuses an e-invoice or cannot receive one has no right to a paper or PDF invoice instead. You have met your obligation once you have issued the e-invoice and can show the attempt to deliver it.
From when do I have to send e-invoices at all?
You have had to be able to receive them since 1 January 2025; an email inbox is enough. You have to issue them to other businesses in Germany from 1 January 2027 if your prior-year turnover was over €800,000, otherwise from 1 January 2028. Small businesses under § 19 UStG and invoices up to €250 are exempt. Federal authorities have required e-invoices since November 2020.
How do I tell what I have received?
An XML file opens in our XRechnung Viewer, a PDF in our ZUGFeRD Viewer. Both show the invoice in readable form; the Validator says which rule set it checked the file against and whether it meets it.
Our free generator makes an XRechnung or a ZUGFeRD PDF from details entered once, for an authority or a business, checked with the KoSIT validator before you download it.
Sources: Ministry of Finance letter of 15 October 2024 (paras. 27, 31, 32, 42), amended on 15 October 2025; federal e-invoicing FAQ; KoSIT, XRechnung versions; FeRD, ZUGFeRD 2.5.2. Read on 25 October 2026. This page explains; it is not tax advice.