XRechnung vs ZUGFeRD vs PDF: which format to use in Germany

First answer: what counts as an e-invoice in Germany

The German BMF FAQ defines an e-invoice as a structured electronic format that enables electronic processing and complies with EN 16931 or is interoperable with it. A plain PDF is still an electronic document, but since January 1, 2025 it is classified as a “non-e-invoice” (sonstige Rechnung), not as a structured e-invoice.

That is why the practical question is not "Can I email a PDF?" but "Can my process generate structured invoice data that the recipient can process and a validator can check?"

The formats most teams should care about

• XRechnung: a German EN 16931 CIUS supplied as UBL or CII XML. Use it when the recipient or portal requires XRechnung, and confirm which syntax and routing fields it accepts.
• ZUGFeRD / Factur-X: a PDF/A-3 file with embedded CII XML. Use a profile the recipient accepts; MINIMUM and BASIC WL do not qualify as German e-invoices under the BMF rules.
• UBL and CII: XML syntaxes, not substitutes for the recipient profile. XRechnung supports both; ZUGFeRD / Factur-X uses CII. A Peppol channel can require Peppol BIS Billing in UBL.

How to choose the right format

1. Start with the recipient requirement, not your preferred format. Some recipients or channels are explicit.
2. Choose XRechnung when the recipient or delivery channel requires it; then confirm its accepted UBL or CII syntax and buyer reference.
3. Choose ZUGFeRD when the recipient accepts the chosen profile and a readable PDF is useful alongside structured data.
4. For Peppol, follow the required Peppol BIS Billing profile and endpoint rules rather than sending generic UBL.
5. Validate the output with the relevant rule set before you decide the format is ready for production.

What does not solve the problem on its own

• Sending a standard PDF and assuming it has become compliant because it was created electronically.
• Picking one format globally without checking the recipient channel or buyer requirement.
• Manually editing XML after validation failures instead of fixing the source data or mapping logic.
• Skipping a review step for invoices with weak source quality, discounts, mixed VAT treatments, or missing buyer identifiers.

Official baseline for Germany

Use the BMF FAQ on Germany’s mandatory e-invoicing rules from January 1, 2025 as the legal baseline for domestic B2B invoicing. For practical rollout, pair that legal view with your recipient requirements, validator output, and internal exception process.