Peppol BIS Billing 3.0 and XRechnung: Interchangeable Within Germany

E-invoicing in Germany is becoming more flexible. With the integration of XRechnung requirements into Peppol BIS Billing 3.0, both formats are now considered content-equivalent. This means Peppol BIS Billing 3.0 and XRechnung can be used interchangeably for e-invoicing in Germany. It’s a significant step toward greater interoperability and digital efficiency in the B2G landscape.

What is Peppol BIS Billing 3.0?

OpenPeppol is a member-driven, non-profit organization responsible for the development, maintenance and global implementation of the Peppol specifications and services. Originally launched as a European Union project to streamline electronic business document exchange across Europe, OpenPeppol has evolved into a globally recognized network.

The Peppol BIS Billing 3.0 format is based on the Universal Business Language (UBL), complies with the EU Directive 2014/55/EU and supports standardized, cross-border electronic invoicing. Invoices are transmitted via the Peppol network using certified Access Points within the 4-corner model. The goal is to enhance interoperability and digital efficiency in electronic invoicing across Europe.

4-corner model of Peppol

What is XRechnung?

XRechnung is the mandatory standard for electronic invoices submitted to public authorities in Germany. It’s based on a structured XML format and fully aligned with the requirements of EU Directive 2014/55/EU.

As a semantic data model, XRechnung defines precise mandatory fields and validation rules to ensure consistency and compliance. Transmission typically takes place via centralized invoice submission platforms such as ZRE (for federal authorities) or OZG-compliant solutions provided by the individual federal states. The primary goal of XRechnung is to enable secure, fully digital and seamless electronic invoicing processes within the public sector.

The table below outlines the key differences between Peppol BIS Billing 3.0 and XRechnung.

Functional equivalence of Peppol BIS Billing 3.0 and XRechnung

Now that we’ve looked at the differences between Peppol BIS Billing 3.0 and XRechnung, let’s turn to what they have in common. These shared characteristics form the basis for their recognition as functionally equivalent and interchangeable within Germany.

Both formats are based on the European standard EN16931, which defines the semantic core of an electronic invoice. This standard specifies the required content of an e-invoice, regardless of the syntax used or the transmission method. As a result, Peppol BIS Billing and XRechnung share a common functional foundation, even if they differ technically.

With the German e-invoicing regulation in 2020, Peppol BIS Billing 3.0 was officially recognized as compliant, provided that the data it contains meets the requirements of XRechnung. That’s because XRechnung is not a fixed file format, but rather a semantic data model that can also be represented using Peppol.

Although both models are based on UBL, they differ in their profile definitions and validation rules. For a Peppol invoice to be accepted in Germany, it must:

• Include all mandatory fields defined by the XRechnung standard
• Be validated through appropriate platforms, such as OZG-compliant portals

By using Peppol, companies benefit from a standard that supports electronic invoice exchange both nationally and internationally. This leads to greater efficiency and reduces administrative effort, especially when working with public sector clients and international business partners.

Key adjustments introduced in the Peppol BIS Billing 3.0 extension

With the introduction of XRechnung version 3.0, initial elements from Peppol BIS Billing 3.0 had already been adopted. With the OpenPeppol release from November 2024 that has been live since February 17, 2025, the process is moving in the other direction, as well. Business rules from XRechnung have been officially incorporated into Peppol BIS Billing 3.0 as country-specific rules for Germany.

This extension forms the “German National Ruleset” (DE-NRS). It includes all XRechnung rules that are technically and semantically feasible within the Peppol network. National rulesets only apply when one or both parties involved are based in the respective country. For the German ruleset, this means that both the buyer and the supplier must be located in Germany. The determining factor is the country code in the respective address data.

In addition, existing validation rules within Peppol BIS Billing were adjusted to support its use as a fully equivalent alternative to XRechnung in Germany. Two key examples include:

• PEPPOL-EN16931-P0100: The invoice types “326” (credit note) and “384” (invoice) are permitted when both parties use “DE” as their country code.
• PEPPOL-EN16931-R002: Multiple entries in the “Invoice Note” element are allowed, provided both the sender and recipient are based in Germany.

These adjustments reinforce the content-level equivalence of both formats and lay the foundation for legally compliant and efficient invoice exchange via Peppol, even within Germany.

Limitations of the National Ruleset

Despite the expanded compatibility between Peppol BIS Billing 3.0 and XRechnung, there are technical limitations that must be taken into account during implementation.

The country-specific rules of the DE-NRS can only be applied using the OASIS UBL 2.1 syntax, as Peppol BIS Billing exclusively standardizes and fully supports this format. Organizations that use XRechnung in the alternative UN/CEFACT CII syntax must rely on the traditional XRechnung implementation. In this case, transmission via Peppol BIS Billing is not possible.

Additionally, the XRechnung 3.0 Extension, which goes beyond the scope of the European standard EN16931, is not interchangeable. These specific extensions are not supported by Peppol BIS Billing and are therefore only available within the XRechnung format.

Two formats, one goal – efficient e-invoicing

Since both formats are based on EN16931 and share aligned validation rules, Peppol BIS Billing 3.0 and XRechnung are now content-equivalent and interchangeable within Germany. This gives companies greater flexibility and makes it easier to standardize their e-invoicing processes.

SEEBURGER supports you with a comprehensive e-invoicing solution that reliably covers XRechnung, Peppol and country-specific requirements. With our certified Peppol Access Point, automated validation services and flexible ERP integration, you’re fully equipped for e-invoicing.

Source: https://blog.seeburger.com/peppol-bis-billing-3-0-and-xrechnung-interchangeable-within-germany/