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E-RECHNUNG

ZUGFeRD: one file, two layers, one legally decisive record

ZUGFeRD answers the most human objection to e-invoicing: nobody wants to read XML. It packs a structured EN 16931 data record and a normal-looking PDF into a single file, so people see an invoice and systems see data. The catch is that the two layers are not equals: since the BMF letter of October 15, 2025, the embedded XML is the legally authoritative representation. This guide covers the format, its profiles and versions, and what that hierarchy means in practice.

Last updated: September 16, 2026

What ZUGFeRD is

ZUGFeRD, short for Zentraler User Guide des Forums elektronische Rechnung Deutschland, is the hybrid e-invoice format maintained by FeRD, the Forum elektronische Rechnung Deutschland. Technically it is a PDF/A-3 document, the archival PDF flavor that may carry file attachments, with a UN/CEFACT CII XML invoice embedded inside. One file travels; humans read the PDF layer, software reads the XML.

The format is developed jointly with France: ZUGFeRD and Factur-X are technically identical standards published in lockstep by FeRD and the French FNFE-MPE. The current release, ZUGFeRD 2.5.2, corresponds to Factur-X 1.09.2; both were published on August 4, 2026 and are valid from September 1, 2026. For cross-border invoicing with France this identity is a quiet superpower: the same file satisfies both national conventions.

The profiles, and which qualify as e-invoices

ZUGFeRD comes in profiles of increasing data depth. The profile decides how much of the invoice exists as structured data, and therefore whether the file satisfies the statutory e-invoice definition. Per the BMF guidance, ZUGFeRD qualifies from version 2.0.1, with the two thinnest profiles excluded:

ProfileQualifies as E-Rechnung?
MINIMUMNo; carries too little structured data (booking aid only)
BASIC WLNo; header data without line items
BASICYes; structured line items for simple invoices
EN 16931 (formerly COMFORT)Yes; the full core invoice model, the standard B2B choice
EXTENDEDYes; adds fields beyond the core model for complex cases
XRECHNUNGYes; a reference profile aligned with the German B2G requirements

Configure issuing software to profile EN 16931 or higher unless you have a documented reason not to; MINIMUM and BASIC WL files are legally sonstige Rechnungen and will not satisfy your issuing duty.

Versions: a fast-moving standard

ZUGFeRD iterates faster than most compliance software assumes. Version 2.4 became effective in January 2026 and added sub-line-item support; version 2.5 followed on June 10, 2026, and the current 2.5.2 of August 4, 2026 is a corrigendum that mainly cleans up EXTENDED-profile features introduced with 2.5, which was itself extended to support the French B2B reform and the revised EN 16931 data model.

Two practical consequences. First, check which version and profile your software actually exports rather than trusting a "ZUGFeRD-ready" label; a 2.0-era export is still a valid e-invoice, but sub-line items and newer fields will silently not exist. Second, on the receiving side your parser must tolerate the whole version range, because your suppliers will collectively send everything from 2.0.1 to current.

The XML is the invoice

Before the reform, German practice treated the visible PDF as the invoice. That has flipped: per the BMF letter of October 15, 2025, the structured XML part of a hybrid invoice is the legally decisive representation, and the visible layer is subordinate. If the PDF says €1,190 and the XML says €1,910, the XML is what you have legally received.

Everything operational follows from that sentence. Processing must read the XML, not OCR the PDF layer. Validation applies to the XML against EN 16931. And archiving must preserve the structured part unaltered in its original form for eight years; filing the printed PDF and discarding the data record fails the requirement. The archiving guide covers the GoBD mechanics in detail.

Where ZUGFeRD fits, and where it does not

ZUGFeRD’s sweet spot is a mixed partner landscape: the same file serves the craft business that prints invoices and the automated AP department that never looks at them. That makes it the transition-friendly B2B choice while the mandate phases in through 2028. For public-sector customers, XRechnung remains the reference; for fully automated high-volume relationships, pure XML avoids the temptation of manual PDF handling altogether. The comparison guide weighs the two formats decision by decision.

On the receiving side you do not get to choose: from 2025, compliant e-invoices of any format may arrive without your consent. Talonic’s invoice processing unpacks ZUGFeRD hybrids, reads the authoritative XML, validates it, and resolves it into the same schema-validated output as XRechnung files, Peppol invoices, PDFs, and scans, with confidence and provenance per field.

Frequently asked questions

Is a ZUGFeRD invoice a valid E-Rechnung?+

Yes, from version 2.0.1 and in the profiles that carry full structured data: BASIC, EN 16931 (formerly COMFORT), EXTENDED, and XRECHNUNG. Per the BMF guidance, the MINIMUM and BASIC WL profiles do not satisfy the statutory definition, they count as sonstige Rechnungen.

Are ZUGFeRD and Factur-X the same thing?+

Technically yes: they are the same Franco-German hybrid standard, published jointly by FeRD and FNFE-MPE under two names. ZUGFeRD 2.5.2 corresponds to Factur-X 1.09.2, both published August 4, 2026. A compliant file in one convention is compliant in the other.

Which layer counts if PDF and XML disagree?+

The XML. Since the BMF letter of October 15, 2025, the structured part of a hybrid invoice is the legally authoritative representation and the visible PDF is subordinate. Your process should book, validate, and archive from the data record.

Which ZUGFeRD version is current?+

Version 2.5.2, published August 4, 2026 and valid from September 1, 2026, a corrigendum to 2.5 of June 10, 2026. Earlier qualifying versions remain valid e-invoices; the version mainly matters for which fields your export can carry.

Can my customers refuse ZUGFeRD and demand XRechnung?+

In domestic B2B, no: since January 1, 2025 every business must be able to receive compliant e-invoices, and a qualifying ZUGFeRD profile is one. The BMF FAQ is explicit that no receiving exceptions are foreseen. Public-sector customers are the exception in practice, since their submission channels are built around XRechnung.

Sources

Primary sources, last checked September 2026. Statutory texts and BMF publications are authoritative; where guidance rests on the BMF letter of 15 October 2025, the text says so.

This guide is general information for businesses, compiled from the cited official sources. It is not legal or tax advice; for decisions about your own obligations, consult your tax advisor (Steuerberater).

One inbox, every invoice format, one schema

The mandate makes structured formats the norm, but your accounts payable will keep receiving paper scans and plain PDFs beside XRechnung and ZUGFeRD for years. Talonic normalizes that mixed inflow into one schema-validated output: typed fields, a confidence score, and provenance on every value, processed on EU infrastructure in Germany. Send a sample batch and judge the output field by field.