XRechnung

Germany's national CIUS (Core Invoice Usage Specification) of the European e-invoicing standard EN 16931, published and maintained by KoSIT (Koordinierungsstelle für IT-Standards — Coordination Office for IT Standards) on behalf of Germany's IT Planning Council. XRechnung is a pure XML format — containing only structured, machine-readable data with no human-readable PDF component — and therefore requires dedicated software or an ERP system to display. Its companion format ZUGFeRD embeds the same XML inside a human-readable PDF/A-3 file; both satisfy Germany's e-invoicing mandate.

What it is

XRechnung supports two XML syntax variants aligned with EN 16931: UBL (Universal Business Language) and UN/CEFACT CII (Cross-Industry Invoice). KoSIT also serves as Germany's Peppol Authority, giving it oversight of both XRechnung and Germany's participation in the Pan-European Peppol network (KoSIT, invoice-portal.de, 2026).

The current version in force is XRechnung 3.0.2, effective from 31 January 2026 (as-of 2026-07-30). A plain PDF does not qualify as an e-invoice under the German definition from January 2025 onwards (VATupdate, 2026-02-19).

Legal basis

Germany's B2B e-invoicing mandate was introduced through the Growth Opportunities Act (Wachstumschancengesetz), which entered into force on 28 March 2024, amending Section 14 of the German VAT Act (UStG) (Trustpair, 2026). From 1 January 2025, §14 para. 1 UStG (as amended) defines an electronic invoice as an invoice issued, transmitted, and received in a structured electronic format that enables automated electronic processing. The format must comply with Directive 2014/55/EU — specifically EN 16931 — as set out in §14 para. 1 sentence 6 UStG n.F. (EY, 2024/2025).

B2B mandate timeline (as-of 2026-07-30)

Phase	Date	Obligation	Scope
Phase 1	1 January 2025	Receive structured e-invoices compliant with EN 16931	All VAT-registered businesses in Germany, no exceptions including small businesses (Kleinunternehmer)
Transition	2025–2026	Issuance remains optional; paper invoices and non-compliant PDFs still permitted for issuance	All businesses; no penalties for paper during this window
Phase 2	1 January 2027	Issue structured e-invoices for domestic B2B transactions	Businesses with prior-year annual turnover above €800,000
Phase 3	1 January 2028	Issue structured e-invoices for domestic B2B transactions	All businesses regardless of size

Sources: VATupdate (2026-02-19, 2026-07-01), EDICOM (2026), VATupdate FAQ (2026-03-26).

The mandate applies only to domestic B2B transactions between German VAT-registered businesses. Foreign businesses only VAT-registered in Germany (without a permanent establishment) are not required to issue German e-invoices but must be able to receive them (VATupdate, 2026-02-19).

Exemptions from issuance obligation

Exemptions include: small-value invoices below €250; travel tickets (Fahrausweise); and transactions by small businesses (Kleinunternehmer under §19 UStG). All exempt categories must still be able to receive structured e-invoices (VATupdate, 2026-02-19).

Accepted formats (as-of 2026-07-30)

As of 2026, the permitted formats for compliant German e-invoices are:

XRechnung (current version 3.0.2, effective 31 January 2026)
ZUGFeRD (from version 2.0.1 onward, EN 16931 profile required)
Peppol BIS 3.0 — content-equivalent to XRechnung for domestic B2B
EN 16931-compliant EDI (where both parties agree)

(e-rechnung.tools, 2026)

ZUGFeRD minimum compliant version: Some sources state ZUGFeRD 2.0.1+ is compliant (e-rechnung.tools, 2026); others imply ZUGFeRD 2.1 is the practical floor for full EN 16931 conformance. The legal text references EN 16931 conformance rather than a specific ZUGFeRD version, so version thresholds should be treated as volatile. (e-invoice.app vs ecosio, 2026)

XRechnung vs ZUGFeRD

The key structural difference is that ZUGFeRD is a hybrid format — a PDF/A-3 file with embedded XML — making it both human- and machine-readable, while XRechnung is pure XML and machine-readable only (Docuflair, 2026). ZUGFeRD's XRECHNUNG profile generates a hybrid PDF/A-3 file whose embedded XML maps directly to the XRechnung schema, meaning a single ZUGFeRD file can satisfy both format requirements simultaneously.

XRechnung is primarily required for B2G (business-to-government) invoice submission to public authorities; ZUGFeRD is considered the more pragmatic choice for B2B transactions because recipients without specialized software can still read the PDF layer (Docuflair, 2026).

A ZUGFeRD 2.1 invoice using the EN 16931 profile is also a valid XRechnung (ecosio, 2026).

ZUGFeRD 2.5 was officially released on 20 May 2026 (recommended for use from 1 July 2026). It adds support for gross invoices (Bruttorechnungen) relevant to the book trade, publishing, and petroleum sectors, and incorporates updated French B2B mandate requirements — it is technically identical to Factur-X 1.09 (capevision.de, 2026). (as-of 2026-07-30)

Peppol integration

Peppol BIS Billing 3.0 and XRechnung are considered content-equivalent for German e-invoicing purposes, meaning either format can be used interchangeably for domestic B2B transactions (SEEBURGER, blog post).

Peppol as delivery infrastructure: ecosio (2026) is explicit that Peppol is NOT mandated by the amended UStG as a delivery channel and that no central German B2B e-invoicing platform exists — the law specifies format compliance (EN 16931) but not delivery infrastructure; businesses may exchange via email, EDI, API, or Peppol. However, some sources (e.g., peppolvalidator.com, cleartax.de) frame Peppol registration in a near-mandatory way and describe Peppol as the primary B2B delivery channel. The ecosio position is corroborated by EY and VATupdate's reading of the legal text. (ecosio, EY, VATupdate 2026 vs peppolvalidator.com, cleartax.de)

Peppol version deprecation (as-of 2026-07-30): All XRechnung versions up to and including 2.1 were changed to "Removed" status in the Peppol network on 1 August 2026; KoSIT strongly recommends all Peppol participants migrate to XRechnung 3.0 immediately. XRechnung versions 2.2 and 2.3 (excluding the XRechnung UBL Credit Note V2.2, V2.3, and V3.0 Extension profiles, which were removed 1 August 2026) are expected to be deactivated no earlier than 2027, following publication of the updated EN 16931 standard (docnova.ai, 2026).

B2G mandate (pre-existing)

Germany's B2G e-invoicing mandate has been in force since 2020, requiring all public sector entities to receive and process structured invoices compliant with EN 16931. At federal level, invoices are submitted via the ZRE (Zentrale Rechnungseingangsplattform des Bundes) or the OZG-RE portal with XRechnung as the required format (Facturwise, 2026).

XRechnung 4.0 (announced — not yet published as-of July 2026)

In March 2026, KoSIT announced XRechnung 4.0, describing it as a "grundlegende Weiterentwicklung" (fundamental development) rather than a bugfix, based on the updated EN 16931-1:2026 European standard (as-of 2026-07-30). Final publication is expected mid-to-late 2026, pending CEN approval of updated UBL 2.5 and CII D25A syntax bindings (invoice-portal.de, 2026).

Key additions in XRechnung 4.0 (volatile — pre-publication):

Removes the strict "one order — one delivery — one invoice" rule, enabling aggregate invoices combining multiple orders and deliveries for the first time (e-invoice.app, 2026)
Adds new fields for detailed bank details, multiple payment terms, early payment discounts (Skonto), and late payment penalties — fields described as required for ViDA (VAT in the Digital Age) real-time reporting (invoice-portal.de, 2026)
XRechnung 4.0 and OpenPeppol's forthcoming Peppol BIS 4.0 will share the same foundation (EN 16931-1:2026), representing a convergence of the German national CIUS and the pan-European Peppol format (invoice-portal.de, 2026)

The revised EN 16931-1:2025 was approved in October 2025 and passed its formal CEN vote in February 2026, adding support for multiple purchase orders per invoice, early payment discounts, late-payment charges, margin schemes, dedicated IBAN fields, and triangulation indicators (VATupdate, 2026-05-25).

July 2026 policy development

On 16 July 2026, German Finance Minister Lars Klingbeil and Justice Minister Dr. Stefanie Hubig jointly presented a 26-point Action Plan against tax and financial crime, with structured e-invoice data feeding a central AI-powered tax platform for fraud detection, 15-year record retention, and a real-time VAT reporting system. VATupdate described it as "a catalogue of intentions, not enacted legislation," with first draft laws expected as early as August 2026 (VATupdate, 2026-07-23). (as-of 2026-07-30)

Implementation and compliance

Risk of non-compliance: The most significant consequence is loss of input VAT deduction — businesses unable to receive or issue compliant e-invoices risk being unable to recover input tax (ecosio, 2026). German law also provides for fines of up to €5,000 per offense for not issuing an invoice in the prescribed form or not issuing it on time (as-of 2026-07-30) (EDICOM, 2026).

March 2026 BMF FAQ update: Germany's Federal Ministry of Finance updated its e-invoicing FAQ in March 2026 to clarify that e-invoices must be "self-contained" — all references and data must be included within the invoice itself, not linked externally (VATupdate, 2026-05-07).

Delivery channel: Because Peppol is not mandated as delivery infrastructure, businesses are free to exchange e-invoices via any channel — email, EDI connection, API integration, or Peppol — so long as the format is EN 16931-compliant (ecosio, 2026).

Practitioner guidance for 2026: Ecosio advises treating 2026 as the year to strengthen receiving, validation, and archiving capabilities — then using the remaining transition window to standardise issuance workflows and onboard trading partners ahead of the 2027 and 2028 deadlines (ecosio, 2026).

Key terms

Term	Meaning
CIUS	Core Invoice Usage Specification — a national or sectoral restriction of EN 16931
KoSIT	Koordinierungsstelle für IT-Standards — the German body that authors and maintains XRechnung and acts as Germany's Peppol Authority
UStG	Umsatzsteuergesetz — German VAT Act
Kleinunternehmer	Small business operator (§19 UStG) — still required to receive e-invoices despite being exempt from issuance obligation
ZRE	Zentrale Rechnungseingangsplattform des Bundes — Federal central invoice receiving platform
OZG-RE	An alternative federal invoice receiving portal
Wachstumschancengesetz	Growth Opportunities Act (2024) — the legislative vehicle for Germany's B2B e-invoicing mandate
EN 16931	EU semantic data model and core invoice standard (Directive 2014/55/EU); updated EN 16931-1:2026 is the base for XRechnung 4.0
ZUGFeRD	Zentraler User Guide des Forums elektronische Rechnung Deutschland — hybrid XML/PDF e-invoice format; France's equivalent is Factur-X

Benchmarks / timeline (as-of 2026-07-30)

Milestone	Date	Detail
B2G mandate in force	2020	Federal and state public authorities must receive EN 16931 invoices
Growth Opportunities Act enacted	28 March 2024	Amends §14 UStG; creates B2B mandate framework
Phase 1 — receive	1 January 2025	All German B2B businesses must receive e-invoices
XRechnung 3.0.2 effective	31 January 2026	Current specification version
ZUGFeRD 2.5 recommended	1 July 2026	Successor to 2.3.3; adds gross invoices and Factur-X 1.09 alignment
Peppol v≤2.1 removed	1 August 2026	KoSIT mandates migration to XRechnung 3.0 on Peppol
26-point action plan	16 July 2026	Germany signals ViDA-aligned real-time VAT reporting arc
Phase 2 — issue (large)	1 January 2027	Businesses >€800k turnover must issue
XRechnung 4.0 expected	Mid-to-late 2026	Based on EN 16931-1:2026 (pending CEN final approval)
Phase 3 — issue (all)	1 January 2028	All German B2B businesses must issue

What practitioners report

Ecosio recommends treating 2026 as the receiving, validation, and archiving year — building robust inbound processing before the issuance deadlines hit (ecosio, 2026).
VATupdate (2026-07-13) notes that businesses can comply without an expensive ERP — lightweight e-invoicing service providers can handle the formatting and channel requirements.
SEEBURGER and Cleo position their EDI/B2B integration platforms as the practical delivery layer for XRechnung at scale, particularly for retailers with complex supplier networks.

Dangling frontier topics

ZUGFeRD — companion hybrid format; referenced throughout this page; no standalone vault page
CIUS (Core Invoice Usage Specification) — the extensibility mechanism of EN 16931; referenced 3+ times; no standalone page
Factur-X — French equivalent of ZUGFeRD 2.5 / identical to ZUGFeRD 2.5 technically; no standalone page
Peppol BIS 4.0 — forthcoming unified pan-European format converging with XRechnung 4.0; no standalone page