ZUGFeRD vs XRechnung: Germany's e-invoice rules explained

In Germany, invoices between businesses are moving to structured electronic formats. Since 1 January 2025, every German business has to be able to receive an e-invoice (E-Rechnung), and the obligation to issue them is phased in until 2028. If you work as a freelancer in Germany, two names come up again and again: XRechnung and ZUGFeRD.

What counts as an e-invoice

The legal basis is § 14 UStG (the German VAT Act), rewritten by the Wachstumschancengesetz for supplies after 31 December 2024. An e-invoice is an invoice that is issued, transmitted and received in a structured electronic format that allows electronic processing (§ 14 (1) UStG, as of October 2026). The format must follow the European standard for electronic invoicing (EN 16931), or one agreed between the parties that allows the required details to be extracted correctly and completely.

Anything else, meaning paper or an unstructured file such as a plain PDF, is an "other invoice" (sonstige Rechnung). All mandatory VAT details have to be in the structured part; a reference to an attachment that holds them is not enough (BMF FAQ, as of October 2026).

XRechnung vs ZUGFeRD

XRechnung is Germany's national implementation of EN 16931, built for invoices to public authorities and also usable between businesses. It narrows the European standard with national rules and supports two syntaxes, UBL 2.1 and CII (KoSIT, XRechnung, as of October 2026).

ZUGFeRD is a hybrid format: a PDF/A-3 document with the invoice data embedded as XML (FeRD, as of October 2026). Its French twin is Factur-X; FeRD describes the two as technically identical. ZUGFeRD comes in profiles of increasing detail, including MINIMUM, BASIC WL, BASIC, EN 16931 and EXTENDED (FeRD, ZUGFeRD 2.5.2, as of October 2026).

According to the Federal Ministry of Finance (BMF), XRechnung and ZUGFeRD from version 2.0.1 qualify as e-invoices, except the profiles MINIMUM and BASIC-WL. With a hybrid invoice, the XML is now the leading part: if the PDF image and the XML disagree, the XML counts.

Deadlines: receiving and issuing

• Receiving, since 1 January 2025: every domestic business must be able to receive e-invoices. There are no exceptions; small businesses under the Kleinunternehmer rule are covered too. An email inbox is enough (BMF FAQ, as of October 2026).
• Issuing, until 31 December 2026: any business may still send paper invoices, or another electronic format such as a PDF if the recipient agrees (§ 27 (38) UStG, as of October 2026).
• Issuing, until 31 December 2027: this option is extended for businesses whose total turnover (Gesamtumsatz) in the previous calendar year was no more than €800,000. Existing EDI procedures may also be used until then.
• From 2028: after the transition periods, e-invoices are mandatory for supplies between domestic businesses.

Even then, some invoices need not be e-invoices: small-amount invoices up to €250 gross (§ 33 UStDV), tickets that count as invoices, and invoices issued by Kleinunternehmer. Invoices to private consumers are not affected (BMF FAQ, as of October 2026).

What it means for small businesses

If you buy from other businesses, you will receive more and more XML or hybrid invoices. In practice:

• Keep the original file. Under § 14b (1) UStG, incoming invoices are kept for eight years, and for an e-invoice at least the structured part must be kept unaltered in its original form, according to the BMF FAQ. A printout or a screenshot of the PDF is not the original.
• Make the XML readable. An XRechnung has no PDF. The tax administration offers a free e-invoice viewer via ELSTER, and other free viewers exist.
• Check which part is which. For a ZUGFeRD invoice, the XML data is the binding part.

How Bonro reads e-invoices

For e-invoices, Bonro skips OCR and reads the structured data directly. It parses ZUGFeRD, XRechnung (CII and UBL), UBL, FatturaPA (Italy) and Facturae (Spain). Supplier, amounts and VAT come from the XML, and every field stays editable. You can forward invoices by email to your private @in.bonro.app address or upload them on the web dashboard.

Reading e-invoices is available on every Bonro plan; see pricing for what each plan includes. From there the invoice flows into the same exports as your photographed receipts, for example the DATEV booking batch for your Steuerberater.