KudTax Blog

E-invoicing 2026: XRechnung & ZUGFeRD in e-commerce

Tarik Türker17.07.202610 min read
E-invoicing 2026: XRechnung & ZUGFeRD in e-commerce
Contents

E-invoicing is no longer a future topic in German B2B trade — it is daily reality. Since January 1, 2025, every business established in Germany must be able to receive e-invoices. 2026 is the last full year of the transition period, and from 2027 the obligation to issue them phases in. If you sell to business customers online, or receive invoices from suppliers, agencies and carriers, you need both directions under control: processing structured invoices and generating them.

This article covers the current state of the deadlines, the difference between XRechnung and ZUGFeRD — and how to handle both in practice without media breaks.


What counts as an e-invoice — and what doesn't?

Germany's Growth Opportunities Act (Wachstumschancengesetz) rewrote § 14 of the VAT Act. Since then, an e-invoice is an invoice in a structured electronic format that conforms to the European norm EN 16931 (or is interoperable with it) and allows electronic processing.

The flip side: a plain PDF invoice is not an e-invoice. Like paper, it now only counts as an "other invoice" and may be used in domestic B2B trade only during the transition period.

Two format families dominate in Germany:

  • XRechnung — a pure XML format with no visual layer, originally the standard for invoices to public authorities (B2G), now increasingly common in B2B. Technically, XRechnung exists in two syntaxes: UN/CEFACT CII and OASIS UBL. Both carry the same EN 16931 content.
  • ZUGFeRD / Factur-X (from version 2.0.1) — a hybrid format: a human-readable PDF with a structured XML file (typically factur-x.xml) embedded inside. For machines — and for tax purposes — only the XML counts.

Important: even with ZUGFeRD, the XML part is authoritative. If the visible PDF and the embedded XML disagree, the XML wins.


The deadlines: who must do what, and when?

The legislator deliberately staged the rollout. As of mid-2026 the roadmap looks like this:

FromWhat applies
Jan 1, 2025All domestic businesses must be able to receive e-invoices. An e-mail inbox is sufficient.
2025–2026Transition period for issuing: paper is still allowed, PDF & co. with the recipient's consent.
Jan 1, 2027Issuing becomes mandatory for businesses with more than €800,000 prior-year turnover.
Jan 1, 2028Issuing becomes mandatory for all domestic B2B transactions.

Exemptions include B2C sales, small-amount invoices up to €250 and passenger tickets. Small businesses (Kleinunternehmer) must be able to receive e-invoices but may continue issuing "other invoices".

That makes 2026 the year of preparation: sellers above the turnover threshold must be ready to deliver within months — and everyone else is already receiving structured invoices, whether they like it or not.


What does this mean for e-commerce specifically?

Online sellers are hit by both sides of the mandate:

On the inbound side, more and more suppliers, fulfilment providers, carriers and agencies are switching to XRechnung or ZUGFeRD. You have to accept these invoices and process them in a compliant way — "we just print the XML" is not a solution, because machine-readable also means: keep it machine-readable.

On the outbound side, the mandate covers every B2B slice of your business: wholesale customers, business buyers on Amazon Business, B2B orders in your own shop, or recharges to partners. By 2028 at the latest — from 2027 if your prior-year turnover exceeds €800,000 — these customers need a real e-invoice from you.

The practical hurdle is rarely the law itself but the workflow: XML files can't be "quickly typed into a spreadsheet", and producing a pretty PDF is no longer enough.


Receiving e-invoices: a 1:1 import instead of AI guesswork

For scanned paper receipts, AI-powered text recognition is a blessing. For an e-invoice it would be a step backwards — the data is already structured and unambiguous. That is exactly how KudTax treats the import:

  • XRechnung XML (both CII and UBL) is parsed deterministically — field by field, with no AI estimation. Whatever the invoice declares as <Seller>, <TaxTotal> or a line item lands 1:1 in the invoice form.
  • ZUGFeRD PDFs are detected automatically: the embedded XML (e.g. factur-x.xml) is extracted and taken over exactly — the AI document reader is skipped entirely for these files. No guessing, no confidence scores, no transcription errors.
  • Before anything is saved you get a preview and stay in control: the invoice is only created once you confirm the import.
  • If something looks off during parsing — say, totals that don't match the line items — KudTax shows hints referencing the official EN 16931 rule IDs (e.g. "BR-CO-15" with the affected BT field numbers). You see not just that something is inconsistent, but which rule of the norm is involved.

The reception mandate turns into an advantage: incoming e-invoices are captured faster and more accurately than any PDF ever was.


Generating e-invoices: XRechnung, UBL or ZUGFeRD — per invoice

For the outbound side, KudTax generates an e-invoice from any invoice directly in the invoice table — in three formats:

  • XRechnung (CII XML) — the classic XRechnung format, using the XRechnung 3.0 profile
  • XRechnung (UBL XML) — the same content in UBL syntax, if your recipient prefers it
  • ZUGFeRD / Factur-X (PDF) — a readable PDF with embedded EN 16931 XML, for recipients who want "something to look at"

The system keeps the mandatory fields in mind: master data such as IBAN and BIC flows into the payment block, and there is a dedicated field for the Leitweg-ID (the norm's BT-10 buyer reference) for public-sector orders. Before the download, KudTax checks the invoice against core EN 16931 business rules and shows you hints if something is missing — without blocking you.

In all honesty, this also belongs here: the e-invoice is produced as a downloadable file. You send it through your usual channel — in B2B, plain e-mail is sufficient. Automatic transmission over networks such as Peppol is currently not part of KudTax.


Checklist: what to sort out in 2026

  1. Test reception: if an XRechnung arrives by e-mail, can someone on your team open, check and book it?
  2. Check the turnover threshold: was your 2026 turnover above €800,000? Then the issuing obligation applies from January 1, 2027.
  3. Identify B2B customers: which of your customers are businesses? They will need structured invoices from you.
  4. Pick your formats: XRechnung for authorities and purist recipients, ZUGFeRD for everyone who expects a readable PDF.
  5. Complete your master data: VAT ID, IBAN/BIC and addresses must be accurate — the norm makes them mandatory fields.
  6. Sort out archiving: e-invoices must be retained in their original format — the XML itself, not just a printout.
  7. Connect your processes: the real gain comes when import, payment matching and the monthly close run digitally end to end.

Conclusion: 2026 is the year preparation pays off

The e-invoicing mandate is not a surprise — it has been reality since 2025 and will be fully rolled out by 2028. For e-commerce it is less a bureaucratic scare than an efficiency opportunity: structured invoices can be imported 1:1 without AI guesswork, matched against payments automatically, and generated per invoice as XRechnung, UBL or ZUGFeRD.

With KudTax you cover both directions in one workflow — from XML import with EN 16931 hints to a finished e-invoice straight from the invoice table. You end up not just compliant, but faster than before.