Needs to be running, level, and the drain plug removed.
What you're meant to do is dump all the oil out with the engine off, by removing the drain plug and level tube, then put the level tube back in, then fill it back up from the bottom with 5L. Start it up, get the gearbox oil temp up to 35-ish deg, and let the excess drain out. Then refit the drain plug.
It's not a hard job to do, but when you don't do it the way VW says to do it, it gets unnecessarily complicated.
'07 Transporter 1.9 TDI
'01 Beetle 2.0
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