Germany XRechnung 4.0: What Changes in the New e-Invoice Specification?

Germany has published a preliminary XRechnung 4.0 specification with more than 50 new business terms and new options for buyer references, XML attachments, discounts, third-party charges and delivery data. It is not for production use, the final bundle is expected in spring 2027.

The preliminary specification for XRechnung 4.0 was published on September 15, 2026, giving software providers, invoice issuers and other users an early view of the changes planned for the next major version of Germany’s XRechnung e-Invoicing standard. The pre-version is intended for preparation and analysis only.

This distinction is important for implementation planning. XRechnung 3.0 remains the version currently in force, and it will remain applicable until at least July 31, 2027. The final XRechnung 4.0 specification and its technical components are currently expected in spring 2027.

XRechnung 4.0 reflects the revised European standard EN 16931-1:2026. The semantic data model has been expanded by more than 50 Business Terms. An earlier official update also states that seven new Business Groups have been added to the revised European model.

The preliminary specification identifies several changes that can affect how structured invoice data is generated, mapped and validated. One change concerns BT-10 “Buyer reference”, which can be provided multiple times and can include an optional Scheme Identifier. XML attachments will also be permitted within the core invoice.

The existing treatment of early-payment discounts will be replaced by the new BG-35 “Early Payment Discount”, giving this information a dedicated structured Business Group. XRechnung 4.0 also introduces BG-34 “Charges on Behalf of a Third Party”, allowing charges or claims made on behalf of third parties to be represented within the invoice data.

Further changes include the possibility of providing more detailed delivery information and referencing multiple orders and multiple deliveries within a single invoice. These additions allow more complex business transactions and invoice relationships to be represented directly in structured e-Invoice data.

For ERP, accounting and e-Invoicing providers, these are more than editorial changes. New Business Terms, Business Groups and changed cardinalities can affect internal data models, field mappings, interfaces, validation rules and invoice-generation processes. However, because the September document is a pre-version, it should currently be used for impact assessment and preparation rather than as the basis for a production migration.

The specification itself is not the complete implementation package. Development of the technical components required for XRechnung 4.0 depends on further work by the European Committee for Standardization (CEN).

The required syntax-binding documents have now been published, while the CEN validation artefacts are still pending. Once those validation artefacts are available, development of the technical components can be completed and the XRechnung 4.0 bundle can be released. Publication is currently expected in spring 2027.

The precise transition arrangements for XRechnung 4.0 are therefore not yet fully established. Earlier official guidance stated that the exact XRechnung transition periods will be determined within the broader EN 16931 transition framework and communicated when the XRechnung 4.0 bundle is published.

Impact on retailers, ERP providers and e-Invoicing systems

The immediate impact is primarily on businesses and software providers that create, receive, transform or validate XRechnung invoices. ERP and e-Invoicing solutions should assess whether their existing data models can accommodate repeated Buyer References, multiple order and delivery references, structured early-payment discounts, third-party charges, XML attachments and more detailed delivery information.

For retailers, the relevance is strongest where XRechnung is used within structured invoicing processes connected to ERP, accounting or central invoicing systems. The preliminary XRechnung 4.0 specification does not introduce a new POS fiscalization or fiscal receipt requirement. The changes concern structured e-Invoice data and the systems responsible for generating, processing and validating it.

This distinction is relevant for retail technology planning. A retailer may not need to change the checkout transaction itself, but invoice data originating from sales, ordering or ERP systems may eventually require new fields, mappings and validation logic when XRechnung 4.0 becomes operational.

What should affected businesses do now?

Businesses should not implement the XRechnung 4.0 pre-version in production. Instead, ERP providers, e-Invoicing providers and businesses issuing XRechnung invoices should use the preliminary specification to identify data-model gaps, affected interfaces and development work that may be required once the final specification and validation components become available.

From a retail and e-Invoicing compliance perspective, the main point is not to treat the September release as a migration deadline. It is an early implementation document intended to give software and business teams time to understand the expanded EN 16931 data model. The more substantial implementation work will depend on the final specification, CEN validation artifacts, technical bundle and confirmed transition arrangements.

The official source for this article is the XRechnung specification, pre-version 4.0.0. Source

Ivana Picajkić, Medior Legal Consultant at Fiscal Solutions

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