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Germany: KoSIT Publishes the Preliminary XRechnung 4.0.0 Specification Built on EN 16931-1:2026, With the Final Release Expected in Spring 2027

KGT Country Update | 2 October 2026 | VAT, e-invoicing and SAF-T monitor

On 15 September 2026, KoSIT, the Coordination Office for IT Standards under the Bremen Senator for Finance, published the preliminary version of the XRechnung 4.0 specification (XRechnung-4.0.0-Vorversion-2026-09-15), the first public view of the German e-invoicing specification built on the revised European standard EN 16931-1:2026.

It is explicitly not for productive use, and the final release is expected in spring 2027.

This is a technical development within the existing legal framework. It changes no legal obligation, but it signals the semantic and syntax changes that German invoice software, and ultimately mandatory B2B and B2G invoices, will have to support once the final version is released and mandated.

Background

XRechnung is Germany’s national core invoice specification (CIUS) of EN 16931. XRechnung 3.0 has been in force since 1 February 2024. Germany’s B2B e-invoicing obligation, introduced by the Growth Opportunities Act and applied through BMF guidance, accepts XRechnung alongside ZUGFeRD and Factur-X, with the issuing obligation phased in to 2028.

The exact content of the structured data therefore matters to every business invoicing in Germany.

The European standard itself has moved. According to KoSIT, EN 16931-1:2026 has been available in English since March 2026, with the German translation from DIN expected by 30 September 2026. KoSIT states that the new version brings more than 50 new business terms and seven new business groups.

The Legislative Change

This is a technical release, not a legislative one. XRechnung 4.0 operates within the existing legal framework: no statute or ministerial letter changes with the publication of the preliminary version.

It is nonetheless relevant in practice because the data model that receiving systems must be able to process, and that validators will test, follows from the specification once it is final.

KoSIT itself describes the purpose of the preliminary version as giving stakeholders the earliest possible overview of functionality that changes against XRechnung 3.0, including requirements the new core model cannot support.

KoSIT also reports that the XRechnung 3.0 line continues: the bundle XRechnung 3.0.2 Summer 2026 Bugfix was published on 31 August 2026, and there was no normative release in summer 2026.

Scope

  • Semantic model. More than 50 new business terms are added to the semantic data model.

  • Buyer reference. BT-10 “Buyer reference” may occur multiple times, with an optional scheme identifier.

  • Attachments. XML attachments are permitted in core invoices.

  • Early payment discount. New rules on early payment discount through the new business group BG-35 replace the previous discount provisions.

  • Third-party charges. A new BG-34 “Charges on Behalf of a Third Party” is introduced.

  • Delivery and references. Enhanced delivery information, and multiple purchase order and delivery references per invoice.

  • Syntax bindings and validation. The syntax binding documents have been published; the CEN validation artifacts are still pending.

  • Language. The preliminary document is predominantly in English because the German translation of EN 16931-1:2026 became available only after it was prepared; full German text will follow in the final version.

Timeline

  • March 2026 — EN 16931-1:2026 available in English.

  • 31 August 2026 — XRechnung bundle 3.0.2 Summer 2026 Bugfix published.

  • 15 September 2026 — preliminary specification XRechnung 4.0.0 published; announced on the KoSIT portal on 16 September 2026.

  • By 30 September 2026 — German translation of EN 16931-1:2026 expected from DIN.

  • October 2026 — HTML comparison view of the changes expected.

  • Spring 2027 — final XRechnung 4.0 release expected, together with the technical components, subject to CEN validation artifacts.

  • March 2029 — end of the parallel operation period for the two versions of EN 16931-1, as stated by KoSIT.

Businesses Affected

Software vendors and in-house teams that generate or receive XRechnung, ZUGFeRD or Factur-X invoices are affected first, followed by any business that issues or receives German invoices through an ERP such as SAP. Public sector suppliers, who use XRechnung today, are directly exposed.

No transition dates for XRechnung 4.0 have been announced; KoSIT states that specific transition deadlines will be announced with the release of the final bundle.

Required Actions

  • Do not deploy anything based on the preliminary version in production; KoSIT states it is not intended for productive use.

  • Read the preliminary specification and map the new terms against your invoice data: multiple buyer references, early payment discounts, third-party charges and multiple order or delivery references.

  • Review how your ERP represents early payment terms and delivery data, since these are the areas where the model changes most.

  • Ask your e-invoicing vendor or platform provider for their XRechnung 4.0 roadmap and their plan for the parallel operation period.

  • Continue to build to XRechnung 3.0 for current obligations, including the 3.0.2 bundle.

Practical Implications

Because the final release depends on the CEN validation artifacts, the date on which validators and receiving platforms begin to enforce version 4.0 is not yet knowable.

Planning should be based on the spring 2027 target for the final bundle and the March 2029 end of parallel operation stated by KoSIT. The areas of change are mostly additive, which suggests that existing XRechnung 3.0 invoices will remain valid during the parallel period, but KoSIT’s transition rules must be awaited to confirm this.

Expected Next Steps

KoSIT has announced a briefing session on XRechnung 4.0 on its portal and expects to publish an HTML comparison view in October 2026, the German translation of the standard, the remaining CEN validation artifacts, and the final specification bundle in spring 2027. KGT will report transition dates when they are published.

How Can KGT Support You?

KGT delivers SAP-integrated e-invoicing add-ons and SAP Document and Reporting Compliance services for Germany, including generation and receipt of XRechnung, ZUGFeRD and Factur-X invoices from SAP data. We assess the impact of specification changes such as XRechnung 4.0 on your SAP output and inbound processing, and we plan upgrades so that format versions can be switched without redesign.

This country update is provided for general information only and does not constitute tax, legal or professional advice.

Country update for Germany
02 October 2026
Germany
Stay informed about the latest indirect tax developments in Germany, including regulatory changes, compliance requirements, and indirect tax guidance affecting businesses operating locally and cross-border. This page provides a structured overview of country-specific updates, such as new legislation, reporting obligations, digital tax initiatives, and implementation timelines.
These insights help tax, finance, and compliance professionals anticipate regulatory changes, adjust processes and systems, and maintain compliant operations in Germany.