ZUGFeRD is Germany's hybrid electronic invoice format and one of the two official e-invoice standards for German B2B transactions under the mandatory e-invoicing reform introduced by the Wachstumschancengesetz in March 2024. ZUGFeRD is often referred to in German as E-Rechnung, the generic term for electronic invoice, though ZUGFeRD specifically refers to the hybrid format combining a human-readable PDF with a machine-readable XML file. If you invoice German business clients, receive invoices from German suppliers, or need to understand how Germany's phased e-invoicing mandate applies to your business, ZUGFeRD is the format at the centre of the conversation. This guide covers what ZUGFeRD is, how its hybrid architecture works, what the six data profiles mean in practice, the difference between ZUGFeRD and XRechnung, how ZUGFeRD and Factur-X are technically identical, what changed in version 2.4, what Germany's B2B mandate requires and when, and how to generate compliant ZUGFeRD invoices without an ERP.
What ZUGFeRD is
ZUGFeRD stands for Zentraler User Guide des Forums elektronische Rechnung Deutschland, which translates roughly as the Central User Guide of the Forum for Electronic Invoicing Germany. It is a hybrid electronic invoice format that combines a machine-readable XML file with a human-readable PDF/A-3 document inside a single file. Developed by the Forum elektronische Rechnung Deutschland (FeRD), founded on 31 March 2010 in Berlin with the participation of German federal and state ministries, the Federal Chancellery, and leading business associations under the AWV Working Group for Economic Administration, ZUGFeRD was first published in its initial version in June 2014.
The term hybrid is the key to understanding what makes ZUGFeRD different from both a plain PDF invoice and a pure XML format like XRechnung. A ZUGFeRD invoice is a single file containing two complete and simultaneous representations of the same invoice. The first layer is a normal PDF that any person can open, read, print and process visually exactly as they would any other invoice. The second layer is a structured XML file embedded inside that PDF, containing every invoice data field in a format that accounting software, ERP systems, and automated processing pipelines can read and post without any human involvement.
Both layers live inside one file. Neither replaces the other. The PDF is not a wrapper for the XML, and the XML is not a summary of the PDF. They are two complete representations of the same commercial transaction, coexisting in a single document. This hybrid approach is specifically designed for the reality of German business: not every SME has a fully automated accounts payable system, and not every supplier can guarantee their client's systems are ready for pure XML processing. With ZUGFeRD, the recipient can always open the PDF and process it manually if needed, while their software extracts the XML automatically if they have the capability. The same file serves both use cases without modification.
One important legal point confirmed by the German Federal Ministry of Finance (Bundesministerium der Finanzen, BMF): in the event of any discrepancy between the data in the XML layer and the data in the human-readable PDF layer of a ZUGFeRD invoice, the XML content is legally decisive for VAT purposes, including input VAT deductibility. The PDF is the readable representation, but the XML is the authoritative invoice for tax law.
The technical architecture of a ZUGFeRD invoice
The XML structure inside a ZUGFeRD invoice is based on the international UN/CEFACT Cross Industry Invoice (CII) standard. The container is the ISO standard PDF/A-3. The current version, ZUGFeRD 2.4, is based on UN/CEFACT CII D22B and is fully backward compatible with D16B.
PDF/A-3 is a specific archival variant of the PDF standard published by ISO. It is designed for long-term document preservation and permits embedding of arbitrary file attachments inside the PDF container, including XML files. This is the mechanism that makes the hybrid format possible. A standard PDF cannot reliably embed structured data in a way that conforming software can extract consistently. PDF/A-3 provides a defined, standardised method to attach the XML file so that any conforming application knows exactly where to find it and how to process it.
The XML embedded in a ZUGFeRD invoice is named zugferd-invoice.xml. This filename distinguishes a ZUGFeRD invoice from a technically identical Factur-X invoice, where the embedded file is named factur-x.xml. The underlying XML schema, the data model and the profiles are shared between the two formats.
The XML implements the semantic data model defined in EN 16931, the European standard for electronic invoicing published by the European Committee for Standardization (CEN) and mandated by EU Directive 2014/55/EU. EN 16931 defines what data a compliant European e-invoice must contain, regardless of which file format or syntax is used to represent it. ZUGFeRD implements EN 16931 using the CII syntax inside a PDF/A-3 container. This is why a ZUGFeRD invoice is simultaneously a normal PDF, a UN/CEFACT CII document, and an EN 16931-compliant structured e-invoice. For a deeper look at the European standard itself, see our explanation of EN 16931.
The six ZUGFeRD profiles
ZUGFeRD defines six data profiles. Five are shared with Factur-X: MINIMUM, BASIC WL (Without Lines), BASIC, EN 16931 (also called COMFORT), and EXTENDED. The sixth is XRECHNUNG, a ZUGFeRD-specific reference profile that embeds XRechnung-conformant data inside the hybrid PDF/XML container.
The profiles define how much structured data is present in the embedded XML. The visible PDF layer looks the same regardless of which profile is used. What changes between profiles is how much machine-readable information the recipient's software can extract automatically.
MINIMUM contains the bare essentials of invoice identification in the XML: invoice number, invoice date, seller and buyer identification, currency code, and total amounts at document level including net, tax and gross. There are no line items in the MINIMUM XML. MINIMUM is not EN 16931 compliant and is not a valid e-invoice under German VAT law. In Germany, MINIMUM functions only as an accounting aid (Buchungshilfe), not as a legally valid e-invoice under §14 UStG. Sending a MINIMUM profile ZUGFeRD invoice to a German B2B client does not fulfil the e-invoicing obligation under the Wachstumschancengesetz.
BASIC WL, where WL stands for Without Lines, adds richer header-level data including payment terms and tax breakdowns at header level, but still contains no structured line-item data in the XML. Like MINIMUM, BASIC WL is not EN 16931 compliant and is also only an accounting aid under German law, not a valid e-invoice under §14 UStG.
BASIC adds full line-item data to the XML structure, including line identifiers, quantities, net line amounts, unit prices, tax category per line and item descriptions. With BASIC, the recipient's accounting software can extract individual line items from the XML and post them to the general ledger without manual re-entry. BASIC is not fully EN 16931 compliant because it omits certain optional EN 16931 fields.
EN 16931, which ZUGFeRD calls COMFORT, is the ZUGFeRD EN 16931 profile that implements the complete EN 16931 data model and is fully EN 16931 compliant. This is the legally valid choice for German B2B e-invoicing under the Wachstumschancengesetz. It contains all mandatory and conditional fields defined by the European standard, including document-level discounts and charges, purchase order references, billing period information, and the complete tax breakdown at both line and document level. EN 16931 is the recommended profile for German B2B invoicing because it is fully compliant with the legal requirements and ensures interoperability with every EN 16931-capable system across the EU.
EXTENDED contains all EN 16931 data plus additional fields for industry-specific requirements. In ZUGFeRD 2.4, the EXTENDED profile was updated to support tax-compliant sub-line items, allowing invoices to carry grouped line structures such as kits, bundles and composite products where individual components are listed beneath a parent line item, each with their own VAT classification. EXTENDED is primarily relevant for manufacturing, construction, trade and logistics businesses where invoices need to carry granular product and delivery data beyond the EN 16931 core. For most freelancers, service companies and SMEs, EXTENDED provides no practical benefit over EN 16931.
XRECHNUNG is a ZUGFeRD-specific reference profile. It embeds XRechnung-conformant XML data inside the hybrid PDF/XML container. This means the structured XML passes XRechnung validation rules, while still providing a human-readable PDF for recipients who cannot process pure XML. XRECHNUNG profile ZUGFeRD invoices can be submitted to German public authorities that require XRechnung, while still being readable as a normal PDF. This makes it particularly useful for businesses that invoice both B2B clients (who prefer ZUGFeRD) and public authorities (who require XRechnung) from a single invoicing workflow.
An important legal note for German businesses: only the EN 16931 profile (COMFORT), EXTENDED, and XRECHNUNG profiles produce a legally valid e-invoice in the German sense. MINIMUM, BASIC WL and BASIC profile ZUGFeRD invoices are not valid e-invoices under §14 UStG and do not fulfil the obligation under the Wachstumschancengesetz. For a step-by-step walkthrough of what makes a ZUGFeRD file technically conformant and how the embedded XML is generated, see our practical guide to creating a Factur-X / ZUGFeRD compliant invoice.
ZUGFeRD vs XRechnung: what is the difference?
ZUGFeRD and XRechnung are both officially approved e-invoice formats for German B2B and B2G transactions under the Wachstumschancengesetz, and both implement EN 16931. The differences are structural and practical rather than legal.
ZUGFeRD is a hybrid format: a PDF with embedded XML. Both layers are present in a single file. The recipient reads the PDF visually and their software processes the XML. The PDF is always available as a fallback if the recipient's system cannot process the XML automatically. XRechnung is a pure XML format with no human-readable PDF component. It contains only structured data and is designed exclusively for machine-to-machine processing. Without dedicated software, an XRechnung invoice cannot be read by a person.
For German B2B transactions between private companies, both ZUGFeRD and XRechnung fulfil the legal requirement. ZUGFeRD is generally preferred for B2B because the hybrid format reduces friction during the transition period when not all German businesses have automated XML processing in place. For German B2G transactions, invoices to federal authorities must be submitted as XRechnung and routed through the correct government portal with the client's Leitweg-ID routing number. However, the XRECHNUNG profile of ZUGFeRD provides a practical middle ground: it embeds XRechnung-conformant XML inside a readable PDF, combining B2G compliance with human readability.
ZUGFeRD B2G invoicing is accepted at state and municipal level as an alternative to pure XRechnung, making it practical for businesses invoicing both private clients and public authorities from a single workflow. For a deeper side-by-side comparison covering use cases, validation differences and routing, see our ZUGFeRD vs XRechnung guide.
ZUGFeRD and Factur-X: technically identical since 2020
ZUGFeRD and Factur-X, the French national e-invoicing format, are technically identical. This has been true since ZUGFeRD 2.1 and Factur-X 1.0 were jointly published on 24 March 2020 by FeRD and FNFE-MPE. Before that, ZUGFeRD 2.0 released in March 2019 was mostly compatible but had minor differences. From version 2.1 onwards, both formats share the same XML schema based on UN/CEFACT CII, the same five core profiles, and the same PDF/A-3 container structure.
The only differences between a ZUGFeRD invoice and a Factur-X invoice are the name of the embedded XML file (zugferd-invoice.xml versus factur-x.xml) and the brand name. ZUGFeRD adds the XRECHNUNG reference profile which is Germany-specific. France adds the EXTENDED-CTC-FR reference profile for its B2B reform, which is a subset of the EXTENDED profile.
This technical equivalence has a very practical consequence for businesses invoicing both German and French clients. ZUGFeRD cross-border invoicing is simplified by this identity with Factur-X, meaning one format covers both Germany and France without separate tools or separate implementations. The same invoicing software that generates ZUGFeRD 2.4 for German B2B clients also generates Factur-X 1.0.8 for French B2B clients. The XML schema is identical and the only adaptation required is the embedded XML filename. For the French side of the equation, including how the September 2026 mandate, certified PDPs and the EXTENDED-CTC-FR reference profile work, see our complete guide to Factur-X and French e-invoicing.
What changed in ZUGFeRD 2.4
FeRD and FNFE-MPE published ZUGFeRD 2.4 and Factur-X 1.0.8 on 4 December 2025. The new version became effective from 15 January 2026. The update was driven by two parallel requirements.
The first was alignment with the biannual update to the EN 16931 specification. The XML schema basis was migrated from UN/CEFACT CII D16B to D22B in order to correspond more precisely to EN 16931. The update also introduced rounding tolerances allowing permissible rounding inaccuracies so that small deviations in calculated tax amounts are no longer treated as validation errors. Importantly, the content of invoices does not change. Amounts, taxes, line items and mandatory fields all remain the same. The change is purely at the technical XML structure level, and the version remains fully backward compatible with ZUGFeRD 2.3.
The second driver was the need to support complex invoice structures for the German and French mandate implementations. The EXTENDED profile was updated to add tax-compliant sub-line items, allowing invoices to carry grouped product lines such as kits, bundles and composite items where individual components need their own VAT classification. Each sub-line item now carries a clear designation of whether it is relevant for VAT purposes, reducing ambiguity for automated processing. The specification was also updated to address tax aspects raised by the BMF in its statement of 15 October 2025 regarding B2B e-invoicing requirements. New elements were added to the EXTENDED profile to ensure interoperability with the French B2B e-invoicing obligation and the EXTENDED-CTC-FR reference profile.
Businesses do not need to rebuild existing implementations, but invoicing software should be confirmed to generate invoices conforming to the 2.4 schema for invoices dated from 15 January 2026 onwards.
ZUGFeRD and Germany's B2B e-invoicing mandate: the complete timeline
ZUGFeRD is one of the two officially accepted formats under Germany's mandatory e-invoicing reform, alongside XRechnung. The reform was established by the Wachstumschancengesetz (Growth Opportunities Act), passed by the Bundesrat on 22 March 2024. The mandate amended §14 of the German VAT Act (Umsatzsteuergesetz, UStG) to define what constitutes a valid electronic invoice and when it becomes legally required. The mandate applies to domestic B2B transactions between VAT-registered businesses established in Germany. It does not apply to B2C transactions, transactions exempt from VAT under §4 UStG, invoices below €250, passenger transport tickets, or cross-border transactions. For the full list of mandatory fields a German invoice must carry to be legally valid, see our German invoice fields guide.
January 1, 2025: All businesses established in Germany must be capable of receiving structured e-invoices in EN 16931-compliant formats including ZUGFeRD. This is the reception obligation. A business cannot refuse a compliant e-invoice from a supplier. During 2025 and 2026, issuing e-invoices remains optional for most businesses and paper or PDF invoices are still permitted if the recipient agrees.
January 1, 2027: Businesses with prior-year annual turnover exceeding 800,000 euros must issue structured e-invoices for all domestic B2B transactions in scope. Paper and PDF invoices are no longer permitted for these businesses. The accepted formats are XRechnung, ZUGFeRD at EN 16931 profile or higher, and other EN 16931-compliant syntaxes.
January 1, 2028: All remaining businesses regardless of turnover must issue structured e-invoices for domestic B2B transactions in scope. The only businesses exempt from the issuance obligation are those qualifying for the Kleinunternehmerregelung (small business scheme under §19 UStG), which from 2025 applies to businesses with prior-year net turnover not exceeding 25,000 euros and current-year net turnover not exceeding 100,000 euros. For the Kleinunternehmer-specific implications of the mandate, see our Kleinunternehmer e-invoicing guide for 2026. For freelancers and self-employed professionals, our German freelancer e-invoicing guide covers the practical workflow.
Kleinunternehmer in Germany must be able to receive ZUGFeRD invoices from January 2025 even though they remain exempt from issuing structured e-invoices. Even if a Kleinunternehmer does not have to send ZUGFeRD invoices, their larger clients will start sending them from 2027 or 2028 and the Kleinunternehmer must be equipped to receive them.
Germany operates a post-audit model. There is no central government platform that B2B invoices must pass through. Buyers and suppliers exchange invoices directly via agreed channels such as Peppol, email, EDI, or dedicated portals. Tax authorities do not receive a real-time copy by default but can request invoices during an audit. This is fundamentally different from France, which requires all domestic B2B invoices to be transmitted through a certified PDP platform from September 2026.
The retention period for e-invoices in Germany was shortened from 10 years to 8 years by the Fourth Bureaucracy Relief Act (Bürokratieentlastungsgesetz IV), effective from January 2025. E-invoices must be retained in their original electronic format throughout this period, ensuring authenticity, integrity, readability and machine-readability in line with GoBD requirements.
Germany's B2G e-invoicing: federal and state portals
For invoices to German public authorities (B2G), the electronic invoicing obligation predates the B2B mandate. The EU Directive 2014/55/EU required all EU public authorities to accept EN 16931-compliant e-invoices by April 2020. Germany implemented this through a combination of federal and state-level platforms.
At federal level, the ZRE (Zentrale Rechnungseingangsplattform des Bundes) and the OZG-RE portal are the submission channels for invoices to federal ministries and agencies. XRechnung is the required format for federal B2G submissions. The Leitweg-ID is a routing number the client provides to ensure the invoice reaches the correct department within Germany's decentralised public sector invoicing infrastructure. Suppliers must obtain the Leitweg-ID from their public sector client before submitting an invoice.
At state and municipal level, each of Germany's 16 federal states has its own e-invoicing legislation and portal. Most state-level mandates have been implemented since 2020 to 2022, though implementation varies by state. ZUGFeRD is generally accepted at state and municipal level as an alternative to pure XRechnung.
Generating ZUGFeRD invoices without an ERP
To create a ZUGFeRD invoice or generate ZUGFeRD-compliant output from scratch, you need dedicated invoicing software that produces the PDF/A-3 container with a correctly embedded and schema-valid XML file. The right ZUGFeRD software generates both layers automatically from your invoice data, handles the XMP metadata correctly, and validates the output before making it available for download. ZUGFeRD invoices cannot be generated with standard PDF tools, Word, Google Docs or generic invoicing software that produces only PDF output.
For freelancers and self-employed professionals in Germany, ZUGFeRD at EN 16931 profile is the recommended format for all domestic B2B invoicing. Generating a ZUGFeRD invoice without an ERP is straightforward with any invoicing tool that includes ZUGFeRD generation as a built-in feature. For ERP users whose system does not generate compliant ZUGFeRD outgoing invoices natively, a standalone invoicing tool that produces compliant ZUGFeRD output can run alongside the ERP without any integration. The ERP continues handling accounting, purchasing and reporting. The standalone tool handles outgoing compliant e-invoices. For a deeper look at the ERP gap and how to close it, see our outgoing e-invoicing ERP gap guide.
The Mustang Project and Valitool are widely used open-source tools for ZUGFeRD generation and local validation. The FeRD provides official XSD schemas and Schematron artefacts for all profiles at ferd-net.de.
For non-German speakers who need to generate or read ZUGFeRD invoices in English, our ZUGFeRD invoicing guide for non-German speakers covers the practical workflow.
Validation in ZUGFeRD
ZUGFeRD validation operates at three levels: the PDF/A-3 file level, the XML schema level, and the business rule level.
At the file level, the PDF must conform to the PDF/A-3 standard. Tools such as veraPDF validate this. A PDF that does not conform to PDF/A-3 is not a valid ZUGFeRD document even if the embedded XML is perfectly formed.
At the XML schema level, the embedded XML must be well-formed and valid against the XSD schema for the declared profile. ZUGFeRD provides five XSD schemas and Schematron artefacts, one per profile (the XRECHNUNG profile uses XRechnung validation artefacts). The declared profile in the XMP metadata of the PDF must match the actual content of the XML. If an invoice declares itself as EN 16931 profile but contains no line items in the XML, the Schematron validation will reject it.
At the business rule level, Schematron rules check conditions that XSD cannot enforce, such as whether tax totals correctly match the sum of line-item tax amounts, whether a VAT exemption code is accompanied by explanatory text, and whether all fields required for the declared profile and tax scenario are present. The most common ZUGFeRD validation errors are arithmetic mismatches on tax amounts (business rules BR-CO-10, BR-CO-15, BR-CO-16), missing mandatory fields (BR-05, BR-15) and incorrect VAT category codes (BR-S-05, BR-Z-05, BR-AE-05).
The Mustang Validator and Valitool are widely used free open-source ZUGFeRD validators. To validate a ZUGFeRD invoice against EN 16931, upload the file to either tool and check for XSD and Schematron errors before sending to clients or submitting to a portal. The Facturwise validator is a free in-browser alternative that accepts any PDF or XML invoice and produces an instant compliance report with no account required. For a deeper walkthrough of each validation layer, common error codes, and how to fix them, see our Factur-X / ZUGFeRD validation guide.
ZUGFeRD cross-border invoicing
ZUGFeRD cross-border invoicing is simplified by its technical identity with Factur-X. A business invoicing German B2B clients with ZUGFeRD 2.4 at EN 16931 profile is generating invoices that are simultaneously valid for French B2B clients as Factur-X 1.0.8, with only the embedded XML filename differing. This makes ZUGFeRD the natural starting point for any business with both German and French clients.
For Belgian and Dutch clients, ZUGFeRD is not the appropriate format. Belgium has mandated Peppol BIS Billing 3.0 for B2B e-invoicing from January 2026, and the Netherlands uses Peppol extensively for both public and private sector invoicing. Peppol expects pure XML and does not accommodate the hybrid PDF/XML structure of ZUGFeRD. For Belgian and Dutch clients, Peppol BIS 3.0 is the correct format. Both ZUGFeRD and Peppol BIS 3.0 implement EN 16931, so the invoice data is the same. The file format and delivery network differ by country. For the full side-by-side comparison, see our Factur-X and Peppol guide.
UK businesses invoicing German clients are not subject to Germany's B2B e-invoicing mandate because that mandate applies to businesses established in Germany. However, German clients may request or require ZUGFeRD as their preferred format for automated AP processing. Generating ZUGFeRD invoices for German clients is straightforward from any compliant invoicing tool that supports the format.
A single invoicing tool that supports all four major EU formats, ZUGFeRD, Factur-X, XRechnung and Peppol BIS 3.0, covers Germany, France, Belgium and the Netherlands from one account without needing separate tools for each market.
A practical ZUGFeRD compliance checklist
Confirm that your invoicing software generates ZUGFeRD 2.4 at EN 16931 profile or higher. Verify that the embedded XML filename is zugferd-invoice.xml and that the XMP metadata correctly declares the conformance level. Ensure the data in the XML and the data visible in the PDF are consistent, since the XML takes precedence for VAT purposes in the event of any discrepancy. Validate at least one test invoice using the Mustang Validator, Valitool, or the free Facturwise validator before sending to clients. If you invoice German public authorities, confirm whether the client requires XRechnung via ZRE or OZG-RE or whether ZUGFeRD XRECHNUNG profile is accepted, and obtain the Leitweg-ID from the public sector client before submitting. Archive ZUGFeRD invoices in their original electronic format for at least 8 years to comply with German GoBD archiving requirements.
Frequently asked questions about ZUGFeRD e-invoicing
What is ZUGFeRD?
ZUGFeRD (Zentraler User Guide des Forums elektronische Rechnung Deutschland) is Germany's hybrid electronic invoice format. It combines a human-readable PDF/A-3 document with a machine-readable XML file embedded inside a single file. Both layers contain the same invoice data: the PDF for human review and the XML for automated processing by accounting software and ERP systems. ZUGFeRD implements the European standard EN 16931 and is one of the officially accepted formats under Germany's mandatory B2B e-invoicing reform. It has been in use since June 2014 and is technically identical to France's Factur-X format since version 2.1 in March 2020.
Is ZUGFeRD mandatory in Germany?
Receiving ZUGFeRD has been mandatory for all German businesses since January 1, 2025, meaning every business must be capable of processing incoming ZUGFeRD and other EN 16931-compliant e-invoices. Issuing ZUGFeRD becomes mandatory from January 1, 2027 for businesses with prior-year net turnover above 800,000 euros, and from January 1, 2028 for all remaining businesses. Kleinunternehmer, businesses with prior-year net turnover not exceeding 25,000 euros under §19 UStG, are exempt from the issuance obligation but must still be able to receive compliant e-invoices from January 2025.
What is the difference between ZUGFeRD and XRechnung?
ZUGFeRD is a hybrid format combining a human-readable PDF and an embedded XML file in a single PDF/A-3 document. XRechnung is pure XML with no PDF layer, designed exclusively for machine-to-machine processing and cannot be read visually without dedicated software. For German B2B transactions between private companies, both formats are legally valid under the Wachstumschancengesetz. For German B2G invoicing to federal authorities, XRechnung is the required format and must be submitted via ZRE or OZG-RE with the client's Leitweg-ID. ZUGFeRD's XRECHNUNG reference profile provides a practical middle ground: it embeds XRechnung-conformant XML inside a readable PDF, enabling B2G compliance while maintaining a human-readable document.
Which ZUGFeRD profile should I use for German B2B invoicing?
For most businesses, the EN 16931 profile (also called COMFORT) is the correct default. It is the only ZUGFeRD profile that is fully EN 16931 compliant and legally valid as a B2B e-invoice under German VAT law (§14 UStG). MINIMUM and BASIC WL are not EN 16931 compliant and function only as accounting aids in Germany, not as valid e-invoices under the Wachstumschancengesetz. BASIC includes line items but is also not fully EN 16931 compliant. EXTENDED is needed only for businesses with complex multi-component invoice structures such as kits, bundles and composite products. The XRECHNUNG profile is for businesses that need to invoice both German B2B clients and German public authorities from a single workflow.
Is ZUGFeRD the same as Factur-X?
Yes, technically. Since ZUGFeRD 2.1 was published in March 2020, ZUGFeRD and Factur-X have been technically identical formats. They share the same XML schema based on UN/CEFACT CII, the same five core profiles and the same PDF/A-3 container structure. The only differences are the name of the embedded XML file, zugferd-invoice.xml for ZUGFeRD and factur-x.xml for Factur-X, and the brand name. ZUGFeRD adds a Germany-specific XRECHNUNG reference profile and France adds EXTENDED-CTC-FR for its B2B reform. A business already generating ZUGFeRD 2.4 for German clients is already generating the technically identical format to Factur-X 1.0.8 for French clients, with no separate tool or implementation needed.
How do I validate a ZUGFeRD invoice?
ZUGFeRD validation operates at three levels. First, the PDF must conform to the PDF/A-3 standard, checked with tools like veraPDF. Second, the embedded XML must pass XSD schema validation for the declared profile, ensuring all required fields are present and correctly structured. Third, Schematron business rules check that tax totals match the sum of line-item amounts, mandatory fields are populated, and VAT categories are correct. The Mustang Validator and Valitool are widely used free open-source ZUGFeRD validators for local validation. The Facturwise validator also accepts ZUGFeRD invoices and produces an instant EN 16931 compliance report with no account required and no cost.
Do Kleinunternehmer need to use ZUGFeRD?
Kleinunternehmer, businesses with prior-year net turnover not exceeding 25,000 euros under §19 UStG, are exempt from the ZUGFeRD and e-invoice issuance obligation under the Wachstumschancengesetz. They do not need to issue ZUGFeRD invoices. However, they must be capable of receiving ZUGFeRD and other EN 16931-compliant e-invoices from their suppliers since January 1, 2025. From 2027 and 2028, larger clients will start issuing ZUGFeRD mandatorily and a Kleinunternehmer must be equipped to receive and process those invoices even if they remain exempt from sending them.
Can I use ZUGFeRD to invoice French or Belgian clients?
For French B2B clients, ZUGFeRD and Factur-X are technically identical, so a ZUGFeRD 2.4 invoice at EN 16931 profile is simultaneously a valid Factur-X 1.0.8 invoice. The only difference is the embedded XML filename. No additional tool is needed to cover both markets. For Belgian B2B clients, ZUGFeRD is not the appropriate format. Belgium has mandated Peppol BIS Billing 3.0 for B2B e-invoicing from January 2026. Peppol expects pure XML, not a hybrid PDF/XML document. For Belgian clients, generate Peppol BIS 3.0 instead. Both ZUGFeRD and Peppol BIS 3.0 implement EN 16931, so the underlying invoice data is the same. A single invoicing tool that supports ZUGFeRD, Factur-X, XRechnung and Peppol BIS 3.0 covers Germany, France, Belgium and the Netherlands from one account.
Generate ZUGFeRD invoices with Facturwise
Facturwise generates ZUGFeRD 2.4 compliant invoices automatically at the EN 16931 profile. Every invoice you create is a fully hybrid PDF/A-3 file with the structured zugferd-invoice.xml embedded and ready for any German AP system, federal authority via the XRECHNUNG profile, or cross-border use as Factur-X for French clients. No XML configuration, no separate tools, no extra steps. Create your first ZUGFeRD invoice for free.
This article is informational and does not constitute legal, tax, or compliance advice. The Wachstumschancengesetz, §14 UStG implementation details, ZUGFeRD profile requirements, and accepted format specifications continue to evolve, and details may change after publication. For decisions affecting your business, consult a qualified tax advisor (Steuerberater), accountant, or your AP/IT integration partner.