Same look, different content
A classic PDF invoice and a ZUGFeRD 2.x invoice look identical on screen. The difference sits inside: ZUGFeRD 2.x is a PDF/A-3 with an embedded machine-readable XML.
The classic PDF does not have this structured part. It is a picture for humans, nothing else. That is exactly what makes it an “other invoice” under the new definition and not an e-invoice.
What the 2.x versions mean
ZUGFeRD has evolved: from early 1.0 states to 2.0, 2.1, 2.2 and 2.3.x. With the 2.x series ZUGFeRD has technically merged with the French Factur-X and is aligned with the European norm EN 16931.
For practice that mainly means: recipients and accounting can rely on a current 2.x file — provided the profile is right. The version number alone is not the decisive point, the profile is.
The profile decides, not the appearance
ZUGFeRD knows several profiles, from very lean to very detailed. Only from profile EN 16931 (formerly “Comfort”) does the file contain all the mandatory data of a full e-invoice. The lean profiles MINIMUM and BASIC WL deliberately carry less and are not enough as a complete invoice.
That is why knowing that “there is an XML inside” is not enough. It matters which profile — and you cannot tell that from the pretty PDF.
Why the plain PDF has had its day
The legislator wants structured data because they are machine-checkable and make VAT fraud harder. A classic PDF cannot be read reliably, a ZUGFeRD XML can.
That is no harassment for its own sake. It is the reason the PDF tolerance for sending runs out and why receiving structured formats must already work today.
What you should concretely watch
So that ZUGFeRD 2.x works for you:
- On receiving, check whether an XML is embedded at all — otherwise it is just a PDF.
- Watch the profile: at least EN 16931, not MINIMUM or BASIC WL.
- Keep the document as a whole, never just the visible page.
- Do not rely on the version number but on a real check.