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Germany E-Invoice Formats: ZUGFeRD vs XRechnung vs Peppol BIS

Germany E-Invoice Formats_ ZUGFeRD vs XRechnung vs Peppol BIS

Germany e-invoice formats come down to three names: ZUGFeRD, XRechnung and Peppol BIS. ZUGFeRD is a hybrid format combining PDF and XML in one file. XRechnung is Germany’s pure-XML public-sector standard. Peppol is not a format at all, but the network that carries these invoices between sender and recipient.

Germany’s e-invoicing mandate took effect on January 1, 2025, and it keeps expanding in phases until 2028. Along the way, the terms ZUGFeRD, XRechnung and Peppol BIS show up everywhere. Confusion about what each one actually is, how they differ, and which one a given business should use is common.

This guide explains all three without mixing them up, with concrete examples and a decision framework. It is written as a practical reference for companies operating in Germany, particularly those running SAP.

The Basic Distinction First: Format or Transmission Network?

The first step to understanding Germany’s e-invoicing ecosystem is separating two distinct layers. Comparisons that skip this step usually end up wrong.

The format layer determines the technical structure the invoice is built in. ZUGFeRD and XRechnung both sit at this layer. Both define the content and structure of the invoice itself.

The transmission layer determines how the invoice reaches the recipient. Peppol sits at this layer. It is not a format — it is the network invoices travel over to get sent and received.

Keeping these two layers apart is the foundation for choosing the right format and infrastructure. The EU’s own ViDA (VAT in the Digital Age) initiative treats them as separate layers too.

What Is ZUGFeRD?

ZUGFeRD (Zentraler User Guide des Forums elektronische Rechnung Deutschland) is a hybrid e-invoice format developed in Germany. “Hybrid” means a single file carries two layers at once:

  • Outer layer: a human-readable invoice view in PDF/A-3 format
  • Inner layer: structured XML data in the UN/CEFACT CII standard, processed automatically by machines

This structure makes ZUGFeRD particularly attractive during the transition period. Your accounting team can open and read the invoice as a PDF. Meanwhile, your ERP system processes the XML data embedded in the same file automatically. The current version is ZUGFeRD 2.5 (in effect as of July 2026). It is technically equivalent to France’s Factur-X 1.09 standard.

ZUGFeRD Profiles: Not All of Them Count as an E-Invoice

The least understood part of ZUGFeRD is its profile structure. Not every ZUGFeRD file carries the same level of data — the amount of information it contains depends on its profile level. For a ZUGFeRD file to count as a legally valid e-invoice in Germany, it must be generated at least at the EN 16931 profile level.

Profile
Data Scope
Legal e-Invoice?
MINIMUM
Basic identifiers only
No
BASIC WL
Limited line item data
No
BASIC
Basic invoice data
No
EN 16931 (Comfort)
Fully compliant with the EU standard
Yes
EXTENDED
EN 16931 plus additional fields
Yes
XRechnung
Compliant with XRechnung specifications
Yes

Warning: a ZUGFeRD file at the MINIMUM or BASIC profile may technically contain structured data, but it does not count as an e-invoice in the legal sense because it fails to meet the EN 16931 standard. Overlooking this distinction creates real compliance risk.

What Is XRechnung?

XRechnung is the national specification Germany developed in line with the European e-invoice standard EN 16931. In technical terms, it is a CIUS (Core Invoice Usage Specification) — it defines Germany’s own application rules on top of the EU standard.

Its clearest difference from ZUGFeRD: XRechnung is pure XML. It has no PDF component. That means a human cannot read the invoice directly, but machines can process it completely and quickly.

Core Features of XRechnung

  • Pure XML structure: can be generated in UBL 2.1 or UN/CEFACT CII format
  • Mandatory fields: requires more mandatory fields than the ZUGFeRD EN 16931 profile (the Leitweg-ID, for example)
  • Public-sector standard: mandatory for invoicing federal and state-level public authorities (B2G)
  • Current version: XRechnung 3.0.2 (XRechnung 4.0 is expected by the end of 2026)
  • File size: 5-50 KB, much smaller than ZUGFeRD since there is no PDF layer

What is a Leitweg-ID? It is a unique routing number used when sending invoices to German public authorities. It routes the invoice automatically to the correct public body. B2B transactions do not use a Leitweg-ID.

ZUGFeRD vs XRechnung Compared

The two formats are frequently confused, since both rest on the same EU standard (EN 16931). Still, their structural and practical differences matter:

Criterion
ZugFeRD (EN 16931)
XRechnung
File structure
Hybrid: PDF + embedded XML
Pure XML
Human-readable?
Yes (PDF layer)
No (requires a viewer)
Machine-processable?
Yes (XML layer)
Yes
Technical basis
UN/CEFACT CII
UBL 2.1 or CII
EU standard compliance
EN 16931
EN 16931
B2B use
Suitable and common
Suitable but not mandatory
B2G (public sector) use
Accepted*
Mandatory standard
Leitweg-ID required?
No (except B2G)
Yes (for B2G)
File size
150-500 KB
5-50 KB
Ease of transition
High (PDF view is preserved)
Low (requires a fully digital shift)

*ZUGFeRD’s XRechnung profile can be used to send invoices to the public sector.

Equivalent in content, different in format: an invoice generated in ZUGFeRD’s EN 16931 profile carries the same data as one in XRechnung 3.0.2. The difference is that ZUGFeRD also delivers a readable PDF layer alongside that data. This adds meaningful flexibility across Europe’s broader e-invoicing regulations.

What Is Peppol BIS?

Peppol (Pan-European Public Procurement OnLine) is an international infrastructure that lets electronic documents be sent and received securely over a standard network. The easiest way to picture Peppol is as the “postal system” for e-invoices. If ZUGFeRD or XRechnung is the invoice itself (the letter), Peppol is the network that gets that letter to the recipient (the postal service).

Peppol’s 4-Corner Model

Peppol runs on a “4-corner model.” The sending company delivers the invoice to its own Access Point. That Access Point sends the invoice over the Peppol network to the recipient’s Access Point. The recipient’s Access Point then delivers the invoice to the recipient company. Sender and recipient never communicate directly with each other; transmission is encrypted over the AS4 protocol.

MDP Group operates as a certified Peppol Access Point, sending and receiving invoices over this network.

Peppol BIS Billing 3.0

Invoices sent over the Peppol network must comply with the Peppol BIS Billing 3.0 specification. This specification is based on UBL 2.1 and meets the EN 16931 standard. As a result, an invoice generated in XRechnung’s UBL format can be sent directly over the Peppol network.

The reverse is not always true, though: a Peppol BIS-compliant invoice may not contain every mandatory field XRechnung requires (the Leitweg-ID, for example). For that reason, Peppol BIS format alone may not be sufficient for B2G transactions.

When Will Peppol Become Mandatory in Germany?

The Peppol network is not mandatory for B2B transactions in Germany. E-invoices can still be sent by email, portal, or EDI. Even so, the calendar is taking shape:

Date
Status
2025
Peppol not mandatory; ZugFeRD/XRechnung via email is sufficient
2027
Peppol still not mandatory for domestic B2B; de facto need grows for cross-border transactions
2028
Peppol infrastructure takes a central role in the national reporting system design
2030
Under the EU's ViDA regulation, Peppol is expected to become the mandatory backbone for intra-EU B2B

Germany currently has roughly 50,000 registered Peppol endpoints. That is quite low compared with the Netherlands’ 350,000+. This number is expected to rise sharply after 2028, and especially after 2030.

Germany E-Invoice Formats: Summary Comparison

The table below lets you compare ZUGFeRD, XRechnung and Peppol at a glance:

ZugFeRD
XRechnung
Peppol
What is it?
Hybrid e-invoice format
Pure XML e-invoice format
E-document transmission network
Category
Format
Format
Infrastructure/Network
Standard
EN 16931 (CII)
EN 16931 (UBL/CII)
EN 16931 (UBL)
Readability
PDF + XML
XML only
- (not a format)
Primary use
B2B
B2G (public sector)
Cross-border B2B/B2G
Mandatory in Germany?
Suitable format for B2B
Mandatory for B2G
Not yet mandatory

Which Format, and When? A Decision Guide

Answer these three questions in order to pick the right format:

1. Are you invoicing a public authority?
If yes, use XRechnung. Request the Leitweg-ID from the recipient.

2. Does your recipient need a PDF view?
If yes, use ZUGFeRD (EN 16931 profile). It gives you both a readable PDF and automated processing.

3. Are you sending the invoice cross-border within the EU?
If yes, send it over the Peppol network, in XRechnung UBL or Peppol BIS Billing 3.0 format.

If none of the above applies, meaning you are sending a domestic B2B invoice, ZUGFeRD EN 16931 is the most common and practical choice.

Limitation: this decision guide applies only to domestic German and intra-EU B2B/B2G transactions. Transactions with third countries (Turkey or the UAE, for example) involve different format and transmission requirements.

Germany’s E-Invoicing Mandate Timeline

The Germany e-invoicing mandate is being phased in under the Wachstumschancengesetz (Growth Opportunities Act):

Date
Mandate
Scope
1 January 2025
Mandatory receipt of structured e-invoices
All B2B companies
1 January 2027
Mandatory e-invoice issuance
Companies with annual turnover above EUR 800,000
1 January 2028
Mandatory e-invoice issuance
All B2B companies (except exemptions)

This calendar applies only to domestic German B2B transactions. Cross-border (intra-EU) transactions fall under EU regulation, and a separate mandate timeline is expected under the ViDA framework from 2030 onward.

For SAP Users: Choosing the Format and Integrating It

At MDP Group, our projects with companies in Germany show that format choice is shaped mostly by the existing SAP infrastructure. Inside a properly configured SAP integration, format conversion stops being a manual task and becomes fully automatic:

  1. Invoice creation: the invoice is generated in SAP through standard processes
  2. Automatic format conversion: the system converts the invoice to XRechnung or ZUGFeRD format automatically, based on the recipient
  3. Delivery over the right channel: email, the Peppol network, or a portal — routed automatically according to the recipient’s preference
  4. Process tracking: delivery status, recipient acknowledgment, and error handling are all tracked from within SAP

Depending on a company’s existing infrastructure, this integration can run on SAP Public Cloud, Private Cloud, SAP Process Orchestration (PI/PO), or SAP Integration Suite (BTP-based). You can find more detail on the 5-step methodology we follow for Germany’s SAP e-invoicing transition in our dedicated article.

In our experience: the most common mistake SAP users in Germany make is trying to manage format conversion with a separate tool outside SAP. This approach adds process complexity and raises the risk of errors. Integration built inside SAP’s own infrastructure gives you single-point management and full traceability.

Frequently Asked Questions

What is the core difference between ZUGFeRD and XRechnung?

ZUGFeRD is a hybrid format that bundles a PDF and XML together, so both humans and machines can read it. XRechnung is pure XML and can only be processed by machines. Both comply with the European standard EN 16931. ZUGFeRD is generally preferred for B2B transactions, while XRechnung is mandatory for invoicing public authorities (B2G).

Is Peppol a format?

No. Peppol is an e-document transmission network, not a format. Invoices created with ZUGFeRD or XRechnung can be sent over the Peppol network. Think of Peppol as the postal service that delivers the invoice, not the invoice itself. Invoices sent over the Peppol network must comply with the Peppol BIS Billing 3.0 specification.

Does ZUGFeRD’s BASIC profile count as an e-invoice?

No. A legally valid e-invoice in Germany requires ZUGFeRD to be generated at least at the EN 16931 (Comfort) profile level. The MINIMUM, BASIC WL and BASIC profiles contain structured data, but they do not meet the EN 16931 standard, so they do not count as legally valid e-invoices.

Are XRechnung and ZUGFeRD EN 16931 the same thing?

They are nearly equivalent in content: both meet the EN 16931 standard and carry the same invoice data. They differ in format, though: ZUGFeRD presents that data as XML embedded inside a readable PDF, while XRechnung exists only as an XML file. Sending invoices to the public sector requires XRechnung’s additional mandatory fields, such as the Leitweg-ID.

When will Peppol become mandatory in Germany?

As of 2026, Peppol is not mandatory for B2B transactions in Germany. E-invoices can still be sent by email. Under the EU’s ViDA regulation, though, Peppol is expected to become mandatory infrastructure for intra-EU B2B transactions starting in 2030. Companies trading across borders are advised to start preparing their Peppol infrastructure now.

Which e-invoice format should I use in my SAP system?

Once your SAP system is configured correctly, format selection becomes automatic. The system generates invoices in XRechnung or ZUGFeRD format automatically, based on the recipient’s type (public or private) and country. The right SAP integration manages this conversion from a single point.

What does the EUR 800,000 threshold mean?

Starting January 1, 2027, companies in Germany with annual turnover above EUR 800,000 will be required to issue e-invoices for their B2B transactions. Companies below that threshold have until January 1, 2028. Regardless of turnover, though, all companies have been required to receive structured e-invoices since January 1, 2025.

Conclusion

Understanding Germany’s e-invoice formats comes down to three points: ZUGFeRD is a hybrid format (PDF + XML), XRechnung is pure XML and mandatory for public-sector invoices, and Peppol is a transmission network, not a format. The right format choice depends on your recipient’s type (public or private), their geographic location (domestic or EU), and your existing ERP infrastructure.

With the 2027 and 2028 deadlines approaching, it matters more than ever for SAP users to have an integration that manages format conversion automatically from within the ERP. Contact us to work out the right path for your existing SAP infrastructure.

References

FeRD – ZUGFeRD 2.5 Specification
XStandards Einkauf – XRechnung Versions
European Commission – ViDA (VAT in the Digital Age)
FNFE-MPE – Factur-X Standard
Haufe – Elektronische Rechnung wird Pflicht
OpenPeppol – Official Peppol Network


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