Creating and validating XRechnung and ZUGFeRD e-invoices

An e-invoice is an invoice in a structured electronic format allowing electronic processing (§ 14 (1) UStG), like XRechnung or ZUGFeRD; a plain PDF is an "other invoice" (sonstige Rechnung). Since 1 January 2025 you must be able to receive e-invoices; between domestic businesses you must issue them from 2027 if your previous-year turnover was over €800,000, otherwise from 2028.

Last updated: 27 October 2026

In short

Transition: Supplies until end of 2026: an other invoice suffices; in 2027 only if previous-year turnover was at most €800,000.
Exceptions for issuing: among others small amounts up to €250 gross, small business owners and invoices to end consumers.
Checking: Validation is not a condition for tax recognition, but the BMF recommends it.

What is an e-invoice, and what is not?

The VAT Act distinguishes two kinds. An electronic invoice is issued, transmitted and received in a structured electronic format and allows electronic processing. An other invoice is transmitted in another electronic format or on paper (§ 14 (1) UStG).

The Federal Ministry of Finance (BMF) gives a plain PDF document as an example of an other invoice. Since 1 January 2025 such a PDF is therefore no longer an e-invoice. As long as you may still issue an other invoice, it remains a proper invoice for input VAT deduction. For another electronic format the recipient has to agree; paper always works.

Important for e-invoices: a file with format errors does not meet the requirements and counts as an other invoice in another electronic format (BMF letter of 15 October 2025, margin no. 6a). That is why a check before sending pays off.

Duty and transition periods: who must do what, and when?

The rules apply to supplies between domestic businesses, when there is a duty to issue an invoice. Exceptions according to the BMF: invoices to end consumers, many exempt supplies (§ 4 nos. 8 to 29 UStG), small amounts up to €250 gross, tickets, supplies by small business owners (§ 34a UStDV) and supplies to legal entities that are not businesses. If a small business owner switches to standard taxation, they must issue e-invoices from that point on.

Period	Issuing	Receiving
1 January 2025 to 31 December 2026	e-invoice or other invoice (paper any time, other electronic format with the recipient's consent)	must be able to receive e-invoices
1 January 2027 to 31 December 2027	e-invoice; other invoice only if your total turnover in the previous year was at most €800,000	as above
from 1 January 2028	e-invoice	as above

EDI procedures that do not already meet the e-invoice requirements may be used until the end of 2027. The BMF sees no exceptions for receiving: small business owners also have to be able to receive e-invoices. The law does not prescribe how you transmit them. Sending by e-mail works.

Retention: You keep each outgoing and incoming invoice for eight years (§ 14b (1) UStG). For an e-invoice, at least the structured part must remain intact in its original form.

XRechnung and ZUGFeRD: what is the difference?

XRechnung is a pure XML file without a PDF. You need a viewer to read it. The standard is developed by the Coordination Office for IT Standards (KoSIT).
ZUGFeRD is a hybrid format: a readable PDF with embedded structured invoice data. It is developed by the Forum elektronische Rechnung Deutschland (FeRD).

With hybrid invoices, the data in the structured part is authoritative. If it differs from the visible PDF, the XML data counts. All mandatory details must be in the structured part; a link to an external target is not enough (BMF letter, margin no. 35).

Both formats build on the European standard EN 16931. The BMF lists XRechnung and ZUGFeRD from version 2.0.1 as formats that meet the VAT requirements, except the profiles MINIMUM and BASIC-WL.

Creating an e-invoice step by step

Collect the invoice data: the mandatory details under the VAT Act, which in an e-invoice have to be in the structured part.
Choose the format: ZUGFeRD if your customer wants a readable PDF; XRechnung if they ask for a pure XML file, for example a public authority.
Settle the buyer reference: In an XRechnung the field BT-10 (buyer reference) is mandatory. You only need a Leitweg-ID when you invoice a public authority. Between businesses, a placeholder such as "-" is enough for VAT purposes.
Generate the file: with an invoicing program that writes the chosen format.
Validate: see the next section.
Send and keep: for example by e-mail; you keep the structured part unchanged for eight years.

Checking an e-invoice: validation before sending

A validation checks whether the file meets the technical format rules of EN 16931 and the business rules. Business rules are technical rules that check the logical dependencies between the details, for example whether a tax amount fits the tax rate. The BMF writes that validation is not a direct condition for tax recognition but helps to avoid errors, and it recommends running it when you create and send an e-invoice. The BMF does not recommend a specific validation tool.

The BMF distinguishes two kinds of errors:

Format errors do not match the permitted syntax. The file is then not an e-invoice (margin no. 6a).
Business-rule errors are logical errors or missing details, for example a missing mandatory BT-10 in an XRechnung (margin no. 6b). A missing BT-10 alone is irrelevant for VAT (margin no. 35a). If a mandatory VAT detail is missing, though, the invoice is not a proper invoice.

A business owner who exercises the care of a prudent businessperson can rely on the technical result of a suitable validation tool. It is advisable to keep the validation report. Validation does not replace your duty to check incoming invoices for completeness and correctness.

Which tools exist? The KoSIT validator is an open-source program (Apache-2.0 license) that checks XML files against XML Schema and Schematron rules. It is only the engine: the rules come from a separate validation configuration, for example for XRechnung. You can run it as a command-line program, as a local HTTP service or from Java. The tax administration also offers an e-invoice viewer in ELSTER where you can view an e-invoice (XRechnung version 3.0.1). It is a non-binding service for reading, not a seal of approval.

Which mistakes come up often?

Sending a PDF as an e-invoice. A plain PDF is an other invoice.
Missing buyer reference. In an XRechnung BT-10 is mandatory; for authorities it is the Leitweg-ID.
Only looking at the PDF. With ZUGFeRD the structured part counts.
Changing the file after the check. If you edit the PDF or the XML afterwards, validate again.
Forgetting about receiving. An e-mail inbox that accepts e-invoices is enough, but it has to exist.
Relying on a transition period without checking last year's turnover. The €800,000 refers to the total turnover of the previous year.

How VAT GPT helps you with this

In the invoice editor of VAT GPT you choose the output format "ZUGFeRD (PDF)" or "XRechnung (XML)". VAT GPT writes the file for download. In three steps:

Choose the format: ZUGFeRD is a hybrid PDF/A-3 with embedded XML, XRechnung a standalone XML file without a PDF. For XRechnung there is a field "Buyer reference (Leitweg-ID)", which is required for XRechnung.
Wait for the check: Before generating, a technical plausibility check against EN 16931 runs. With XRechnung, the file is generated when the check is passed. With ZUGFeRD, a failed check gives you a PDF without structured data and a notice that it contains no e-invoice.
Download: You download the file and can send it, for example, by e-mail.

VAT GPT reads incoming e-invoices (ZUGFeRD PDF or XRechnung XML) when you upload them. With Free you can create invoices in ZUGFeRD and XRechnung formats. There are Free (basic features, free of charge), Go (30 days free with all Pro features) and Pro (€49 per month or €444 per year), each including VAT. Try for Free Now

Frequently asked questions

What is the difference between XRechnung and ZUGFeRD? XRechnung is a pure XML file. ZUGFeRD is a PDF with embedded XML data. According to the BMF, XRechnung and ZUGFeRD from version 2.0.1 meet the requirements, except the ZUGFeRD profiles MINIMUM and BASIC-WL.

Is a PDF an e-invoice? No. Since 1 January 2025 a plain PDF is an other invoice.

When do I have to issue e-invoices? For supplies from 2027 if your previous-year total turnover was over €800,000, otherwise for supplies from 2028 (§ 27 (38) UStG).

Do I already have to receive e-invoices? Yes, since 1 January 2025. An e-mail inbox is enough.

Do I need a Leitweg-ID? Only for invoices to public authorities. Between businesses a placeholder in the field BT-10 is enough for VAT purposes.

Do I have to validate the e-invoice? It is not a condition for tax recognition, but the BMF recommends it.

How long do I keep e-invoices? Eight years (§ 14b (1) UStG); the structured part has to stay intact.

Does the duty apply to small business owners? Not for issuing, as long as they apply the small business scheme (§ 34a UStDV). They must be able to receive.