EU E-invoicing overview
B2G live since 2020 / B2B from 2025

Germany E-invoicing Guide

XRechnung, ZUGFeRD, Leitweg-ID, the Wachstumschancengesetz B2B mandate, and 10-year retention requirements. Everything you need to invoice German buyers and comply with the law.

Standard

XRechnung / ZUGFeRD

Legal basis

Wachstumschancengesetz

Receive obligation

1 Jan 2025

Send obligation

2027 / 2028

Mandate timeline

Live

2020

B2G mandatory (federal)

XRechnung via Peppol required for all invoices to German federal authorities.

Live

1 Jan 2025

B2B receive obligation

All German VAT-registered businesses must be able to receive structured e-invoices. ZUGFeRD and XRechnung both qualify.

Upcoming

1 Jan 2027

B2B send (over 800k EUR turnover)

Businesses with annual turnover above 800k EUR must send structured invoices. Plain PDFs no longer accepted for B2B.

Upcoming

1 Jan 2028

B2B send (all businesses)

All German VAT-registered businesses must send structured e-invoices. The transition is complete.

Exceptions: Exceptions: Invoices under 250 EUR (Kleinbetragsrechnungen), public transport tickets, and invoices to non-VAT-registered (private) buyers are exempt from the structured format requirement.

XRechnung vs ZUGFeRD: which do you need?

Both formats implement EN 16931 and are legally equivalent for B2B purposes under the Wachstumschancengesetz. The difference is in structure and use case.

XRechnung

  • + Pure XML (UBL or CII syntax), ideal for EDI pipelines
  • + Required for B2G (federal, state, municipal)
  • + Transmitted via Peppol or PEPPOL-DE network
  • - Not human-readable without a viewer
  • - Requires Leitweg-ID for public sector recipients
Validate an XRechnung file →

ZUGFeRD / Factur-X

  • + PDF/A-3 with embedded XML: human AND machine readable
  • + Drop-in for existing PDF invoice workflows
  • + Accepted for B2B (Wachstumschancengesetz)
  • - Larger file size than pure XML
  • - Not accepted for B2G (Peppol requires XRechnung)
Validate a ZUGFeRD / Factur-X file →

Leitweg-ID: the German public sector routing identifier

Every German public authority has a Leitweg-ID, a structured routing identifier in the format XXXXXXXX-YYYY-ZZ. XRechnung invoices destined for a public buyer must carry the Leitweg-ID in field BT-10 (buyer reference).

Without a valid Leitweg-ID, the invoice cannot be routed through the Peppol network and will be rejected by the receiving authority's system.

Leitweg-IDs are public and can be looked up in the official register. Many German municipalities list their Leitweg-ID on their website under the "Lieferanteninformationen" (supplier information) section.

What your accounting software does not provide

Generating a structurally valid XRechnung or ZUGFeRD file is not the same as being legally compliant. These are the gaps most German accounting tools leave open:

Software Generates What is missing
SAP ERP / S/4HANA XRechnung (with SAP DRC module) RFC 3161 timestamp, Legal Hold, chain of custody, Evidence Pack
DATEV Buchhaltungssoftware ZUGFeRD 2.x (basic profiles) PDF/A-3 conformance not always verified, no independent timestamp, no 10-year archival enforcement
Lexware ZUGFeRD 2.x No EN 16931 validation before output, no immutable archival, no audit trail
Sevdesk / Billomat ZUGFeRD MINIMUM/BASIC WL No line-item XML (EN 16931 profile), no qualified timestamp, no retention policy
Odoo Factur-X (ZUGFeRD alias) Community edition: validation optional; no Legal Hold, no tamper-evident archival

10-year retention: HGB 257 and AO 147

Legal requirement

HGB 257 and AO 147 require businesses to retain invoices for 10 years from the end of the fiscal year in which the invoice was created.

The archived document must be stored in a way that ensures it cannot be altered (tamper-evidence) and can be retrieved and verified at any time during the retention period.

What SealDoc provides

  • RFC 3161 timestamp from EU-qualified TSA at the moment of sealing
  • SHA-256 hash chain that proves the document has not changed
  • BUSINESS_7Y / custom retention policy enforced at storage level
  • Legal Hold: prevent deletion even if retention period has not expired
  • Evidence Pack: court-ready bundle with all audit metadata

Frequently asked questions

Is XRechnung mandatory for B2B invoices in Germany?
From 1 January 2025, all German VAT-registered businesses must be able to receive structured e-invoices (XRechnung or ZUGFeRD 2.x). The obligation to send structured invoices applies to businesses with over 800k EUR annual turnover from 1 January 2027, and to all remaining businesses from 1 January 2028.
Can I still send a plain PDF invoice to a German company?
Until 31 December 2026, yes, with the recipient's consent. From 1 January 2027, businesses over the 800k EUR threshold must receive structured invoices only. From 1 January 2028, plain PDFs are no longer accepted for any B2B transaction.
What is the difference between XRechnung and ZUGFeRD for B2B?
For B2B invoicing under the Wachstumschancengesetz, both are legally equivalent: any EN 16931-compliant format is accepted. XRechnung is pure XML (better for EDI), ZUGFeRD is a hybrid PDF with embedded XML (better for human readers). B2G (public sector) requires XRechnung via Peppol.
What is the Leitweg-ID and do I need it?
The Leitweg-ID is a routing identifier used by German public authorities (municipalities, federal agencies, state governments). It must be included in field BT-10 of an XRechnung invoice sent to a public sector buyer. It is not required for B2B invoices.
How long must I retain invoices in Germany?
German law (HGB 257 and AO 147) requires 10-year retention from the end of the fiscal year. The archived document must be tamper-proof and retrievable for the full period. In practice this means the original file plus a cryptographic hash or RFC 3161 timestamp that proves the file has not changed.
My ERP already generates ZUGFeRD. What else do I need?
Your ERP generates the file. SealDoc adds the legal layer: RFC 3161 timestamp from an EU-qualified TSA (proves the document existed at a specific time), a SHA-256 hash chain (tamper-evidence), Legal Hold (prevents accidental deletion), and a complete Evidence Pack for audit or court submission.

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