Alignment to EU’s EN 16931 e-invoice standard; gross invoicing
Germany and France will release ZUGFeRD 2.5 on 20 May 2026.
It lands at a critical point in Germany’s e-invoicing rollout – with January 2027 issuing obligations – and raises the bar for operational readiness.
ZUGFeRD remains a hybrid format: PDF/A-3 with embedded EN 16931 XML.
Human readable and machine processable, Version 2.5 does not change that architecture, nor the German mandate thresholds. But it does tighten alignment with the evolving European data model and expands real-world usability.
2 major change: EN16931; gross billing
Two updates matter:
- Native support for gross invoicing. Sectors such as publishing and petroleum can now issue compliant invoices without workarounds; and
- Alignment with the latest EN 16931 code lists, ensuring continued validation across EU systems.
Further, FeRD has released updated reference templates covering construction, leasing, reverse charge and simplified invoices. These standardise complex scenarios at data-field level, reducing interpretation risk and improving interoperability between ERP, e-invoicing platforms and tax authority validation layers.
Alongside this, the publication of an English version of the ZR (Central Invoice Receipt) framework by OpenPeppol and Germany’s KoSIT removes a long-standing barrier for non-German businesses. This is a clear signal: cross-border participation is expected, not optional.
Convergence to ViDA and VAT compliance
This is not a new legal obligation. The receiving mandate has applied since 1 January 2025. But ZUGFeRD 2.5 exposes who is still not compliant. As Germany moves toward the 2027 issuing requirement, technical standards are converging with ViDA’s 2030 digital reporting model.
For VAT, structured invoice data is no longer downstream. It is the source of truth.
Where VATCalc fits
VATCalc’s single tax engine, reporting and e-invoicing application consumes any invoice format, validates against legislation-coded VAT rules in its tax engine, and outputs compliant e-invoices and reconciled to VAT returns. Or as France and others move to pre-filled VAT returns, reconciled to those, too.
As standards like ZUGFeRD evolve, the challenge is not format conversion. It is ensuring the VAT treatment, reporting and audit trail remain consistent across every transaction and jurisdiction.
