Germany e-invoicing 2027: generate ZUGFeRD from JSON

From 1 January 2027, a business in Germany with more than €800,000 turnover the year before must send e-invoices to other businesses in Germany. From 1 January 2028, every business must, apart from a few exceptions. A ZUGFeRD file counts: a normal-looking PDF with the invoice data inside it as XML. This guide gives the dates from the law and the Federal Ministry of Finance (BMF), then shows how to make a valid ZUGFeRD invoice from JSON with one request.

The dates

The exceptions: invoices up to €250, travel tickets, invoices from small businesses under § 19 UStG, and supplies that are VAT-exempt under § 4 Nr. 8 to 29 UStG. Invoices to private customers are not affected, and EDI may continue until the end of 2027 if the customer agrees.

The newest BMF letter, of 15 October 2026, adds detail but keeps these deadlines. Trade bodies have asked for a delay; as of 7 November 2026 nothing has changed in the law.

What counts as an e-invoice

• The format must follow the European standard EN 16931. XRechnung does, and so does ZUGFeRD from version 2.0.1, except the profiles MINIMUM and BASIC-WL (BMF letter of 15 October 2024, paragraphs 25 and 30).
• A plain PDF is not an e-invoice, however it was made. Every mandatory detail has to be in the XML part.
• A file that fails the schema check counts as an ordinary invoice, not an e-invoice. So validate what you send.
• Email is a valid way to send it. No network or platform is required; you and your customer agree on the channel.

Make a ZUGFeRD invoice from JSON

Send the invoice as data: seller, buyer, lines with quantities, net prices and VAT rates. We calculate the lines, the VAT breakdown and the totals, and return a PDF/A-3 file with the EN 16931 XML inside (Factur-X 1.0, the same standard as ZUGFeRD 2.x).

curl https://api.pagenull.dev/v1/invoices \
  -H "Authorization: Bearer $PAGENULL_API_KEY" \
  -H "Content-Type: application/json" \
  -o INV-2026-0142.pdf \
  -d '{
  "invoice": {
    "number": "INV-2026-0142",
    "issueDate": "2026-11-03",
    "dueDate": "2026-11-17",
    "buyerReference": "PO-7781",
    "seller": {
      "name": "Northwind Studio EOOD",
      "address": {
        "line1": "12 Example Street",
        "city": "Sofia",
        "postcode": "1000",
        "country": "BG"
      },
      "vatId": "BG123456789"
    },
    "buyer": {
      "name": "Acme Robotics EOOD",
      "address": {
        "line1": "1 Vitosha Blvd",
        "city": "Sofia",
        "postcode": "1000",
        "country": "BG"
      }
    },
    "lines": [
      {
        "description": "API integration, October",
        "quantity": 12,
        "unit": "HUR",
        "unitPrice": "85.00",
        "vatRate": 20
      },
      {
        "description": "PDF template design",
        "quantity": 1,
        "unitPrice": "340.00",
        "vatRate": 20
      }
    ],
    "payment": {
      "iban": "BG80BNBG96611020345678"
    }
  }
}'

Keep the default profile, EN16931. BASIC isn’t among the profiles the BMF excludes either. Don’t use MINIMUM for German invoices: the BMF excludes it. The full field list is in the Factur-X and ZUGFeRD guide.

Check the file

Mustang, the free open-source validator from the ZUGFeRD community, checks the PDF/A part and the XML against the official rules. We publish a sample run with its unedited report, so you can run the same check on your own file:

java -jar Mustang-CLI-2.26.0.jar --action validate --source RE-2027-0001.pdf

Public-sector customers

Many public bodies in Germany ask for XRechnung and a Leitweg-ID, sent through their own portal. We put the Leitweg-ID in buyerReference, but we don’t make XRechnung files. Ask the authority which formats it accepts.

Countries where our file isn’t enough

Germany accepts a Factur-X/ZUGFeRD file sent by email. Many countries don’t: they require a specific network or a national system, and we don’t connect to any of them. If you invoice businesses in these countries, you need a provider that does.

We also don’t produce XRechnung or UBL, the XML-only formats, and we don’t send, receive or archive invoices. Peppol access, a national platform and long-term archiving are separate services.

Keep your copy

We store nothing: not the data, the XML or the PDF. German law requires you to keep invoices for years, so archive the file we return, or pass deliverTo to have it uploaded straight to your own storage.