ZUGFeRD and Factur-X update: FeRD and FNFE-MPE publish 2.5.2 and 1.09.2
Paris/Berlin, 20 August 2026. Germany’s Forum elektronische Rechnung Deutschland (FeRD) and France’s Forum National de la Facture Électronique et des Marchés Publics Électroniques (FNFE-MPE) published a new ZUGFeRD and Factur-X update on 4 August 2026. The releases are ZUGFeRD 2.5.2 and Factur-X 1.09.2: two names for one technically identical hybrid e-invoice format. The new versions apply from 1 September 2026, the exact day the French e-invoicing mandate takes effect.
Factur-X and ZUGFeRD combine a fully readable invoice in PDF/A-3 with an embedded XML file following the European standard EN 16931, in UN/CEFACT Cross Industry Invoice syntax D22B. One file therefore serves both the person reviewing the invoice and the system reading it automatically. The format offers five profiles: MINIMUM, BASIC WL, BASIC, EN 16931 and EXTENDED.
What changes in ZUGFeRD 2.5.2 and Factur-X 1.09.2
The 4 August release builds on ZUGFeRD 2.5 and Factur-X 1.09 of 10 June 2026, which followed the half-yearly refresh of the EN 16931 code lists. FNFE-MPE describes the August version as a small number of additions and corrections against June, recorded in a change log.
The most visible addition is sub-line management, which allows subtotal lines and invoice lines for kits, bundles and composite items to be represented in structured form. This matters as soon as a commercial invoice presents an aggregated product while the buyer’s systems need component-level detail. Both bodies describe this as necessary for the reforms in France and Germany.
The release also corrects consistency issues in the EXTENDED profile: revised business rules for the VAT breakdown, corrections to item attributes and rounding, and adjusted cardinality of line-level VAT fields. Each of the five profiles receives updated XSD schemas and Schematron validation artefacts. FNFE-MPE also folded in points from preparatory work by the French tax administration and the AFNOR commission, and from the German Federal Ministry of Finance statement of 15 October 2025.
One detail deserves attention: the August step was published without a press release. Anyone who completed format testing between 10 June and 3 August 2026 tested against a baseline that has since been corrected, and that is the group most likely to miss the change.
DGFiP splits the register of Plateformes Agréées into two lists
Two days later, on 6 August 2026, the French tax administration DGFiP updated its public register of Plateformes Agréées and, for the first time, published it as two separate lists. The first covers operators satisfying all conditions, including interoperability testing in live conditions. The second covers operators whose file is complete and compliant, but whose definitive registration still depends on passing those tests.
That distinction is material. From 1 September 2026 every business established in France and subject to VAT must be able to receive e-invoices through a Plateforme Agréée, with no size threshold and no free public alternative, after the decree of 27 July 2026 removed the public portal as an exchange route. An operator that misses those tests leaves its clients without a transmission route. KGT counted 144 operators on the first list and 17 on the second; the DGFiP itself publishes no official total. For background on the run-up to that date, see our report on the French e-invoicing mandate and the 1 September deadline.
How the ZUGFeRD and Factur-X update relates to Peppol BIS and UBL
A common question is whether this format competes with Peppol. It does not: these are different layers of one chain. EN 16931 is the semantic layer, describing what data an e-invoice contains. Factur-X and ZUGFeRD are a document format: a PDF/A-3 container holding XML in CII syntax. Peppol BIS Billing is also an implementation of EN 16931, but in UBL syntax, extended with rules for addressing and transport across the Peppol network through a Peppol Serviceprovider. In practice Peppol therefore usually carries UBL, whereas Factur-X and ZUGFeRD are file formats that can also circulate outside a network.
In France the two worlds meet. Factur-X is, alongside UBL and CII, one of the three formats in the minimum base that every Plateforme Agréée must be able to receive, as set out in AFNOR standard XP Z12-012. Your outbound flow can stay on Peppol BIS in UBL while your inbound flow may hold Factur-X files. For how the UBL side develops, read our explanation of Peppol BIS 4.0 and the PINT and UBL merger.
What this means for Dutch and Belgian organisations
For finance managers, IT decision-makers and accountants in the Netherlands and Belgium, the exposure is cross-border. If you supply French customers, they will expect processing through a Plateforme Agréée from September, and you may receive Factur-X regardless of what you send. If you supply German customers, receipt of e-invoices has been mandatory there since 1 January 2025, with issuing obligations phasing in from 2027, as set out in our guide to e-invoicing in Germany. In Belgium the 4-corner Peppol model has been live since January 2026; 5-corner is the ambition for 2028.
Four checks remain realistic this month:
- Ask your Peppol Serviceprovider or ERP supplier which version they will produce and accept on 1 September, and when the new validation artefacts move into production.
- Refresh the embedded code lists. A stale code list is a common and avoidable cause of rejection, since Schematron validates against it strictly.
- Re-run format validation, including negative testing, against the 1.09.2 and 2.5.2 artefacts. Results from June or July are superseded.
- Check whether your French platform sits on the first or the second DGFiP list, and if on the second, request a written status on its interoperability testing.
Technical validity is not the same as tax compliance: invoice content, retention and authenticity controls remain governed by national legislation. The ZUGFeRD and Factur-X update mainly affects the toolset you use to generate and validate invoices, and that toolset needs to be correct on 1 September. To see which providers support this format and the Peppol network, compare them in our independent Peppol provider comparison tool.
Sources
- FNFE-MPE, Factur-X 1.09.2 and ZUGFeRD 2.5.2 common publication (EN), updated 4 August 2026
- FNFE-MPE, Factur-X et ZUGFeRD, joint standard page
- FeRD, ZUGFeRD 2.5.2 English information package
- DGFiP, register of Plateformes Agréées
- DGFiP, facturation électronique et plateformes agréées
- KGT, France: Factur-X 1.09.2 and ZUGFeRD 2.5.2 issued on August 4, 2026, and the DGFiP register split into two lists
- VATupdate, France and Germany publish updated Factur-X and ZUGFeRD specifications
