France and Germany have published an updated version of the common Factur-X and ZUGFeRD e-invoicing format. Released on 4 August 2026, Factur-X 1.09.2 and ZUGFeRD 2.5.2 incorporate the latest EN 16931 updates and changes linked to the e-invoicing reforms in both countries. For businesses preparing for France’s 1 September deadline, the release is another technical update to include in final testing and validation.
Factur-X 1.09.2 and ZUGFeRD 2.5.2 released
The French National Forum for Electronic Invoicing and Electronic Public Procurement (FNFE-MPE) and Germany’s Forum for Electronic Invoicing (FeRD) published Factur-X 1.09.2 and ZUGFeRD 2.5.2 on 4 August 2026.
The two formats are technically identical. Factur-X is the name used in France, while ZUGFeRD is used in Germany. Both combine a human-readable PDF/A-3 invoice with structured XML data that can be processed by financial systems.
The latest release follows Factur-X 1.09 and ZUGFeRD 2.5, published on 10 June 2026. It adds further corrections and adjustments as France and Germany continue implementing their respective e-invoicing requirements.
What has changed in the latest release?
Factur-X 1.09.2 and ZUGFeRD 2.5.2 remain aligned with the European e-invoicing standard EN 16931 and incorporate changes following its biannual update.
A notable addition is support for sub-line management. This makes it possible to represent subtotal lines and invoice lines for kits, bundles and composite items within the structured invoice data. According to FNFE-MPE, these capabilities are needed to support requirements arising from the French and German e-invoicing reforms.
The specification also includes amendments resulting from preparations for the French reform by the French Tax Administration and the AFNOR Electronic Invoicing Commission. On the German side, changes take into account fiscal aspects addressed by the Federal Ministry of Finance.
Why this matters for France before 1 September
The update arrives shortly before the first mandatory phase of France’s e-invoicing reform. From 1 September 2026, all businesses within scope must be able to receive e-invoices. Large enterprises and intermediate-sized enterprises must also issue e-invoices from that date and comply with the applicable e-reporting requirements.
Factur-X is one of the three formats within the minimum base that must be supported for invoice reception in the French framework, alongside UBL and CII. The format is therefore directly relevant to organisations completing their technical preparations for September.
The new release does not change the French implementation deadline or introduce a separate mandate. Instead, it updates a format that forms part of the technical framework businesses and their platforms need to support.
It follows other recent technical developments in France. Dynatos previously covered the latest AFNOR e-invoicing specifications, which provide additional guidance on business scenarios, invoice lifecycle management and operational processes.
More recently, the French authorities also published practical guidance for the start of the mandate. Our overview of how businesses should manage the September e-invoicing go-live explains how organisations should prepare for technical issues, business continuity and compliance during the first phase.
What does the update mean for Germany?
Germany’s B2B e-invoicing framework has been in effect since 1 January 2025, although transitional rules continue to apply to the issuance of e-invoices. Businesses must already be able to receive e-invoices where the rules apply.
ZUGFeRD is one of the formats commonly used to meet the German requirements. The German Federal Ministry of Finance confirms that ZUGFeRD from version 2.0.1 generally meets the VAT requirements for an e-invoice, with the MINIMUM and BASIC-WL profiles excluded.
The 2.5.2 update further aligns ZUGFeRD with EN 16931 and incorporates requirements identified during implementation of the German framework. For organisations operating in both France and Germany, the common technical basis of Factur-X and ZUGFeRD can simplify format management, but it does not remove country-specific regulatory and process requirements.
Where finance and IT teams should focus
For businesses already using Factur-X or ZUGFeRD, the release should trigger a targeted review rather than a redesign of the entire invoice process. The priority is to determine whether existing ERP systems, invoice generation tools, validation components and e-invoicing providers support the latest version correctly.
This review should cover both outbound and inbound processes. On the sending side, businesses need to confirm that structured invoice data is generated according to the correct profile and validation rules. On the receiving side, systems need to extract and process the XML data correctly, including more complex invoice structures such as sub-lines, kits and bundles.
Validation is particularly important. A technically exchanged invoice can still create downstream exceptions when mandatory data is missing, mappings are outdated or structured information cannot be processed correctly by the receiving ERP or AP environment.
For organisations preparing for France, these checks should form part of final end-to-end testing before 1 September rather than being treated as a standalone format update.
Changes companies need to implement for Factur-X and ZUGFeRD
- Confirm whether ERP systems, invoice tools and e-invoicing providers support Factur-X 1.09.2 or ZUGFeRD 2.5.2 where relevant.
- Review mappings and validation rules against the latest EN 16931-aligned specifications.
- Test invoice scenarios involving sub-lines, subtotals, kits, bundles and composite items where these occur in business processes.
- Validate both invoice creation and inbound processing to identify exceptions before they reach finance operations.
- For France, include the updated Factur-X specification in final end-to-end testing ahead of 1 September 2026.
- For Germany, assess the update alongside the applicable B2B e-invoicing requirements and transitional rules.
For a complete overview of the French requirements, implementation timeline and technical framework, visit our French e-invoicing mandate page.
