Germany: ZUGFeRD 2.5 (Factur-X 1.09) Published, with Use of the Updated Hybrid E-Invoice Format from July 1, 2026
In June 2026, the German Forum for Electronic Invoicing (FeRD), together with its French partner FNFE-MPE, published ZUGFeRD 2.5 — identical in content to Factur-X 1.09 — the latest version of the Franco-German hybrid e-invoice format.
The new version is to be used from July 1, 2026, and brings updated code lists, refreshed validation artifacts, and new EXTENDED profile elements designed for interoperability with France’s mandatory B2B e-invoicing regime going live in September 2026.
Background
Since January 1, 2025, all businesses established in Germany must be able to receive structured electronic invoices compliant with EN 16931 for domestic B2B transactions, with issuance obligations phasing in through January 1, 2028. ZUGFeRD/Factur-X is one of the two dominant compliant formats in the German market alongside XRechnung.
As a hybrid format, it embeds a structured XML file (CII syntax) inside a human-readable PDF/A-3, allowing the same document to be processed automatically and reviewed visually. Because the format is jointly maintained with France’s FNFE-MPE, each release also tracks the technical requirements of the French mandate.
The Change
ZUGFeRD 2.5 / Factur-X 1.09 was published in a first release on June 10, 2026, for use from July 1, 2026. The key changes are:
- Mandatory updates of code lists to the current published versions.
- Updated validation artifacts (Schematron rules and schemas) for all profiles.
- New data elements in the EXTENDED profile that are relevant for interoperability with mandatory B2B e-invoicing in France, easing dual-country compliance for businesses invoicing in both markets.
- A second release is announced that will implement the planned functionality for gross-amount invoices, relevant for sectors such as the book trade, publishing, and the mineral oil industry.
Scope
The update affects all businesses issuing or receiving ZUGFeRD/Factur-X invoices in Germany and France, as well as software vendors and service providers that generate or validate the format. Profiles from MINIMUM through EXTENDED and XRECHNUNG are covered by the refreshed validation artifacts.
Timeline
- June 10, 2026 — publication of ZUGFeRD 2.5 / Factur-X 1.09 (first release).
- July 1, 2026 — the new version is to be used in productive exchange.
- Second half of 2026 (announced) — follow-up release adding gross invoice functionality.
- January 1, 2027 / January 1, 2028 — remaining German issuance phase-in dates for mandatory B2B e-invoicing.
Businesses Affected
German businesses that standardized on ZUGFeRD for domestic B2B invoicing, and multinationals using Factur-X for both German and French flows, are directly affected. Companies whose SAP output management or middleware generates ZUGFeRD PDFs must ensure the version upgrade is reflected in their document generation and inbound validation logic. Recipients should confirm their invoice ingestion tools accept 2.5-profile documents without rejection.
Required Actions
- Update invoice generation components (SAP add-ons, output management, middleware) to produce ZUGFeRD 2.5 / Factur-X 1.09 with the current code lists.
- Refresh validation rules in inbound processing so that supplier invoices in the new version validate correctly.
- Businesses in scope of the French mandate should evaluate the new EXTENDED profile elements as part of their September 2026 France readiness.
- Monitor the announced second release for gross invoice support if operating in affected sectors.
Practical Implications
Version upgrades of hybrid formats are operationally sensitive: a sender moving to 2.5 while a recipient validates against older Schematron rules can trigger false rejections and payment delays. Coordinated upgrades across AP and AR, and regression testing of PDF/A-3 embedding and XML extraction, are advisable before the July 1, 2026, use date — and are now urgent for businesses that have not yet upgraded.
Expected Next Steps
FeRD is expected to publish the second part of the release with gross invoice functionality, and further alignment with the French external specifications is likely as France’s mandate goes live. In parallel, German businesses should track BMF guidance on the issuance phase-in toward 2028 and the future interaction with ViDA digital reporting requirements.
How Can KGT Support You?
KGT’s SAP-integrated e-invoicing add-ons generate and process EN 16931-compliant formats, including ZUGFeRD/Factur-X and XRechnung, directly from SAP ECC and S/4HANA. We keep format versions, code lists, and validation artifacts current as releases such as ZUGFeRD 2.5 are published, and our SAP DRC services cover the German mandate end to end — from readiness assessment through configuration, testing, and support. KGT can verify your German and French invoice flows against the latest format requirements.
Official Sources
- FeRD — ZUGFeRD/Factur-X standard (ferd-net.de)
- Fiscal Solutions — Germany: New Version of ZUGFeRD/Factur-X e-Invoice Format Released
This publication is provided for general informational purposes only and does not constitute tax, legal, or professional advice. Please consult your advisor before acting on any information contained in this update.
