E-Invoicing in Germany 2027: XRechnung and ZUGFeRD Explained

Starting 1 January 2027, many German suppliers can no longer send you a plain PDF invoice. From 1 January 2028, that applies to almost all of them. Invoices become structured data: XRechnung files without any visible layout, or ZUGFeRD PDFs with an XML file inside.

For anyone who collects invoices and passes them to bookkeeping, this changes more than the file extension. It changes which file counts as the invoice, what you have to store, and which common habits quietly break compliance.

This guide summarizes the rules as of October 2026 and explains how Invoice Radar will support e-invoices before the 2027 deadline.

The Short Version

• An e-invoice (German: E-Rechnung) is a structured file that follows the European standard EN 16931. A PDF is not an e-invoice.
• The two formats you will see most in Germany are XRechnung (pure XML) and ZUGFeRD (a PDF with embedded XML, also known as Factur-X).
• In a ZUGFeRD file, the XML is the legally relevant invoice. The PDF is only a readable copy.
• You must keep the original XML unchanged for 8 years. Printing an XRechnung to PDF and discarding the XML is not enough.
• Every German business has had to be able to receive e-invoices since 2025. An ordinary email inbox is enough.

The Timeline

There has been no postponement. Trade associations have asked for one, but the legal deadlines remain unchanged as of October 2026.

Because you cannot see a supplier's turnover, expect a mix of PDFs and e-invoices throughout 2027. Large suppliers are already switching: Deutsche Telekom and Deutsche Bahn, for example, have announced that business customers will receive ZUGFeRD invoices by the end of 2026.

XRechnung vs. ZUGFeRD

XRechnung is a pure XML file. It has no layout and is not meant to be read by people without a viewer. It usually arrives as an .xml attachment, sometimes together with a separate PDF copy.

ZUGFeRD (identical to the French Factur-X) is a PDF/A-3 file with an XML file embedded inside. It looks like a normal PDF, so it is easy to treat it like one. The important part is invisible.

ZUGFeRD comes in several profiles. Only BASIC, EN 16931 (COMFORT), EXTENDED and XRECHNUNG qualify as e-invoices. The MINIMUM and BASIC WL profiles do not contain enough data and legally count as ordinary invoices.

How to Spot an E-Invoice in Your Inbox

E-invoices rarely announce themselves. These are the patterns to look for:

• An .xml attachment is most likely an XRechnung. Some suppliers also send it zipped.
• An .xml file and a PDF in the same email usually means an XRechnung with a PDF copy for convenience. The XML is the invoice; the PDF is not.
• A PDF on its own may be a ZUGFeRD invoice. Open it in Adobe Acrobat Reader and check the attachments panel (paperclip icon). An embedded file named factur-x.xml, zugferd-invoice.xml or xrechnung.xml means it is a hybrid invoice.
• A link to a customer portal means the invoice has to be downloaded. Many portals now offer an XRechnung or ZUGFeRD version next to the regular PDF.

If you open the XML and find urn:factur-x.eu:1p0:minimum or basicwl near the top, the file uses a profile that does not count as an e-invoice in Germany.

The XML Is the Invoice

According to the German Federal Ministry of Finance (BMF), the XML part of a hybrid invoice is leading. If the PDF and the XML show different data, the XML wins. Input VAT deduction is based on the XML.

Large differences are a real risk: a PDF with different tax-relevant data can be treated as a second invoice.

In practice, this means one thing: whatever happens to your invoices, the XML must survive untouched.

How to Store E-Invoices Correctly

German VAT law and the GoBD (the principles for digital bookkeeping) set clear rules. The GoBD were amended in July 2025 specifically for e-invoices.

• Keep the original XML unchanged. It must remain machine-readable.
• Retention period: 8 years for invoices and booking vouchers (reduced from 10 years since 2025).
• For ZUGFeRD, storing the XML is sufficient. The PDF part only needs to be kept if it contains additional tax-relevant information. Keeping the entire original file is the simplest way to cover both.
• Conversions are allowed only if the original is preserved. A readable rendering of an XRechnung is a convenience copy, not the invoice.
• The email that only carries the invoice does not need to be archived. If the email text itself contains tax-relevant information, it does.

There is no official GoBD certification for software. The responsibility stays with your business, which is why it matters that every tool in your chain hands over the original file.

Three Mistakes to Avoid

1. Printing an XRechnung to PDF and archiving only the PDF.
2. Treating ZUGFeRD MINIMUM or BASIC WL as an e-invoice. They are not.
3. Ignoring portal invoices. Providing an invoice for download in a customer portal is an accepted delivery method, so those files need to be collected and stored as well.

What We Found Checking Our Own Pipeline

Before announcing e-invoice support, we traced every step an invoice takes through Invoice Radar, from the inbox to the accounting tool. Most weak spots we found are not specific to one product. If other tools handle your invoices, check them for the same issues:

• Attachment filters that only look for PDFs. An email that contains only an XRechnung never enters the workflow, and nobody notices.
• Download handlers that only accept PDFs. When a portal offers an XML download, the download fails silently.
• Features that create a new PDF. Watermarks, merging documents for printing, compression and "print to PDF" all produce a new file without the embedded XML.
• Exports that assume every document is a PDF, for example by forcing a .pdf file name or PDF content type.
• Data extraction that reads the PDF with OCR or AI, even though the exact values are already in the XML.

We are fixing each of these in Invoice Radar before 2027. The rule behind every change: the original file is never modified, and every readable view or converted copy is clearly marked as a copy.

Do You Need to Validate E-Invoices?

Validation is not a legal precondition for receiving an e-invoice. However, you still need to check an invoice for correctness before deducting input VAT. According to the BMF, you may rely on the result of a suitable technical validator, and keeping the validation report is recommended.

The BMF distinguishes two types of errors:

• Format errors: the file is not a valid e-invoice and counts as an ordinary invoice. From 2027, ask the supplier for a corrected one.
• Business rule errors: they only matter if they affect information required for VAT purposes. A missing buyer reference, for example, does not invalidate the invoice for tax purposes.

Which Invoices Are Exempt?

Plain PDFs or paper remain allowed for:

• Small invoices with a total of up to €250
• Travel tickets
• Invoices from small businesses (Kleinunternehmer)
• Invoices from foreign suppliers and invoices to consumers

So even in 2028, your inbox will not be PDF-free. US software subscriptions, foreign suppliers and small receipts will still arrive as PDFs.

What About Peppol and the Rest of Europe?

In Germany, email remains a legal and common delivery channel. Peppol is optional and mainly used for invoices to public authorities.

Elsewhere, the picture differs. Belgium has required Peppol for domestic B2B invoices since January 2026. Since 1 September 2026, all French companies must be able to receive e-invoices through approved platforms. From 1 July 2030, the EU's VAT in the Digital Age (ViDA) package requires structured e-invoices for cross-border B2B sales within the EU.

How Invoice Radar Will Support E-Invoices

Invoice Radar already collects invoices from email inboxes and supplier portals and forwards them to your accounting tools. ZUGFeRD invoices are PDF files, so they are already collected and passed on as original files, including the embedded XML.

Full e-invoice support will ship before the 1 January 2027 deadline. It includes:

• Collecting XRechnung files from email attachments, including emails with both an XML file and a PDF copy
• Downloading the e-invoice version from supplier portals where it is available
• Keeping the original file unchanged, with the XML as the leading document
• Showing XRechnung invoices in a readable layout directly in the app
• Reading invoice data directly from the XML: exact amounts, VAT and invoice numbers without guesswork
• Showing whether a document qualifies as an e-invoice, including profiles like ZUGFeRD MINIMUM that do not
• Forwarding the original e-invoice to your export destinations, such as DATEV, Lexware Office, sevDesk or a folder

We are also evaluating Peppol receiving for teams that need it.

FAQ

When do e-invoices become mandatory in Germany?

Every German business has had to be able to receive e-invoices since 1 January 2025. Suppliers with more than €800,000 turnover in 2026 must issue e-invoices from 1 January 2027. From 1 January 2028, the obligation applies to practically all domestic B2B invoices.

Is a PDF invoice an e-invoice?

No. A PDF without structured data is an ordinary invoice. Only structured formats following EN 16931, such as XRechnung and ZUGFeRD from version 2.0.1 in the BASIC profile or higher, count as e-invoices.

Do I have to keep the XML file of a ZUGFeRD invoice?

Yes. The XML is the legally relevant part and must be kept unchanged for 8 years. The PDF part only has to be kept if it contains additional tax-relevant information, but keeping the original file preserves both.

Can I convert an XRechnung into a PDF for my archive?

You can create a PDF as a readable copy, but you must keep the original XML. Archiving only the converted PDF is not sufficient.

Do I need a special mailbox or Peppol to receive e-invoices?

No. In Germany, a regular email inbox is enough. Peppol is optional for B2B invoices between German businesses.

How can I tell whether a PDF is a ZUGFeRD invoice?

Open the PDF in Adobe Acrobat Reader and look at the attachments panel. A ZUGFeRD or Factur-X invoice contains an embedded XML file, usually named factur-x.xml, zugferd-invoice.xml or xrechnung.xml.

Will Invoice Radar support XRechnung?

Yes. Invoice Radar will support XRechnung and ZUGFeRD before the 1 January 2027 deadline, including collection from email and portals, readable display, data extraction from the XML and forwarding of the original file.

Sources

• BMF letter of 15 October 2025 on mandatory e-invoicing (German)
• BMF FAQ on e-invoicing (German)
• Second GoBD amendment of 14 July 2025 (German)
• Transition rules in § 27 (38) UStG (German)
• XRechnung versions and bundles, KoSIT (German)
• VAT in the Digital Age (ViDA), European Commission

This article reflects the guidance available in October 2026. It is not tax or legal advice. Please check specific cases with your tax advisor.