XRechnung vs ZUGFeRD: Which Format Should a German Freelancer Use?

Germany already flipped the switch on e-invoices. Since 1 January 2025, every domestic business engaged in B2B activity, including a Freiberufler, Einzelunternehmen, or GmbH, must be able to receive an E-Rechnung, with no revenue threshold. The Wachstumschancengesetz (Growth Opportunities Act), passed in March 2024, is the law behind it. Issuing is still phased by prior-year revenue. Clients ask for XRechnung. Software menus offer ZUGFeRD. Your tax adviser says "structured XML." You still want something you can open without feeling like you are reading machine code.

The timeline that actually matters

Germany uses a post-audit model. There is no central government clearance platform you must ping in real time. For receiving, the Bundesfinanzministerium is clear: an email inbox that can accept the file is enough. That is a different world from France's approved-platform model. Retention is eight years under § 14b UStG, and the structured (XML) component must stay intact. Saving only a pretty PDF printout of a ZUGFeRD file is the mistake people will regret in an audit.

What counts as an E-Rechnung

Germany defines an e-invoice as one that meets the European semantic standard EN 16931. The common domestic formats that do: XRechnung, and ZUGFeRD from version 2.0.1 onward except the MINIMUM and BASIC-WL profiles. A plain PDF emailed as an attachment is a sonstige Rechnung, an "other invoice," not an E-Rechnung. During the transition, other invoices are still allowed for issuing until your cohort's deadline. Receiving structured files is already the baseline. See our note on whether a PDF is an e-invoice under EN 16931 for the one-sentence EU answer.

XRechnung vs ZUGFeRD in plain language

XRechnung is pure XML. Machines love it. Public-sector buyers in Germany often require it. You open the file and see tags, not a layout. Without a viewer or import into accounting software, it is hostile to humans. ZUGFeRD is a hybrid: a PDF/A-3 you can read, with EN 16931-aligned XML embedded inside. Same idea as France's Factur-X. In fact they share a Franco-German hybrid lineage. Human-readable and machine-readable in one file.

That is the whole decision for most freelancers. Client is a public authority or a company that explicitly demands XRechnung: send XRechnung (or whatever profile they specify). Client is a normal German GmbH or freelancer and you want one file that both of you can open: ZUGFeRD is usually the saner default. I would pick ZUGFeRD as the freelancer default unless a client contract says otherwise. Pure XML is fine when both sides have tooling. Most solo operators still settle disputes by looking at a visual invoice.

Do I need to care yet?

• Receiving: yes, already. If a supplier sends XRechnung or ZUGFeRD to your business email, you must be able to take it. You do not get to demand paper because you are small.
• Issuing above €800,000 prior-year revenue: mandatory from 1 January 2027. If your 2026 revenue exceeded €800,000, structured e-invoices are required from January 2027.
• Issuing at or below €800,000: you can keep issuing other invoices (paper, plain PDF) through 2027, then structured e-invoices from 1 January 2028.
• Large clients may ask you to send structured invoices early even when the law still allows PDF. Saying yes can be good client management; saying no is still legal until your date.

How ready is the market? In a December 2024 Bitkom release, the association reported that only 45% of 1,103 German companies surveyed could receive structured, machine-readable e-invoices. The survey was a telephone poll of 1,103 companies with at least 20 employees. That gap is why you still see confused email threads in 2026. It is also why documenting what you sent (and in which format) beats assuming the other side "got it."

Kleinunternehmer (§19 UStG) and other exemptions

These carve-outs are about issuing, not about the duty to receive. None of them delete the eight-year retention requirement for structured files you do hold.

• § 19 UStG small-business regime (Kleinunternehmer): if you qualify under the small-business VAT rules, you are generally exempt from the obligation to issue e-invoices for those supplies. You still need to be able to receive. Confirm your status with your tax adviser; § 19 thresholds move over time.
• Invoices up to €250 gross (Kleinbetragsrechnungen): small-amount invoices can stay as other invoices. Useful for tiny one-off B2B charges. Do not build your whole practice on €249 invoices to dodge structure. Auditors can count.
• B2C: invoices to private end customers are outside the domestic B2B e-invoice issuing mandate.
• Many VAT-exempt supplies and qualifying tickets (Fahrausweise) also sit outside the issuing duty per IHK and BMF FAQs. Edge cases belong with your advisor.

A sane freelancer setup

• Business email that you actually monitor.
• Folder or tool that stores the original XML or ZUGFeRD file for eight years, not a flattened PDF printout.
• A viewer or accounting import so XRechnung is not a black box when a supplier sends pure XML.
• Default outgoing format: ZUGFeRD for most private-sector clients; XRechnung when required (especially public sector with Leitweg-ID).
• A note in your onboarding email stating how you send and receive.

You do not need a corporate e-invoicing programme. You need boring reliability. Tools built for solo invoicing help with the day-to-day send, track, and remind loop while you add the format work as your 2027/2028 date approaches.

Quick decision guide

What to tell your clients

"Since 2025 I can receive XRechnung and ZUGFeRD at [your business email]. My outgoing format is currently a PDF while the transitional rules apply. I will issue structured e-invoices from the date that applies to my business. If you need XRechnung specifically for AP, tell me before the first invoice."

If a client sends you pure XRechnung and you cannot read it, say so once, ask for a ZUGFeRD twin or a visual copy in addition, and still archive the structured original. German guidance is explicit that a human-readable PDF sent "as a courtesy" does not replace the duty to keep the structured part.

If you invoice public clients, ask for their Leitweg-ID and preferred XRechnung profile up front. Guessing wastes days.

Your next step

Set up a monitored business inbox and a viewer now. Then ask each recurring client whether they require XRechnung or accept an eligible ZUGFeRD profile. That answer, not a generic format debate, should determine your default. Care about receiving now. Care about issuing by 2027 or 2028 depending on the €800,000 prior-year line in the Wachstumschancengesetz.