Germany’s Federal Ministry of Finance has issued supplementary guidance on mandatory domestic B2B e-invoicing, clarifying VAT data requirements, invoice corrections, industry-specific exceptions and compliance rules. The guidance also extends certain transitional arrangements and confirms that technical validation errors outside mandatory VAT fields do not automatically prevent input VAT deduction.
Germany’s Federal Ministry of Finance (BMF) issued a supplementary letter on mandatory domestic business-to-business (B2B) e-invoicing on 15 October 2026. The letter amends the VAT Implementation Decree (Umsatzsteuer-Anwendungserlass, UStAE) and provides further clarification on the implementation of the e-invoicing mandate.
The rules apply to transactions performed after 31 December 2024, while respecting transitional provisions through 31 December 2027. A general non-objection rule protects e-invoices issued up to 31 December 2026, provided they conform to previous BMF guidance even if they do not meet the additional specifications of the new letter.
The key aspects of the guidance are outlined below.
Advance, interim, and final invoices
- Advance & down payments: Down payment, advance, and interim/installment invoices issued prior to the seller becoming subject to mandatory e-invoicing do not need to be converted into e-invoices, even if final performance or payment occurs after the mandatory mandate kicks in.
- Final invoice relief (Extended to 30 June 2030): For final e-invoices, tax authorities will not challenge invoices where pre-received partial payments are deducted as a total sum in field BT-113 (“Paid amount”), with specific partial payment breakdowns recorded in free-text field BT-22 (“Invoice note”). Alternatively, partial payment deductions can be provided in an embedded, referenced attachment.
Mandatory VAT data & service descriptions
- Field mapping standards: The BMF requires e-invoices to include all mandatory VAT fields under §§ 14 and 14a UStG in their structured data, recommending KoSIT and FeRD mapping tables for EN 16931-1 compliance.
- Audit & control requirements: The structured data must specify the type, scope, content and place of service to support tax assessments and input VAT deduction checks. Detailed supplementary information, such as time sheets, may instead be provided in embedded PDF files or other attachments.
Industry & format provisions (construction, gross prices, discounts)
- Construction invoices: As detailed bills of quantities (Leistungsverzeichnis) cannot currently be accommodated in the EN 16931 core data model, issuers may list individual trades and total amounts in the structured XML, provided an itemised bill is included in a human-readable attachment. Additional structured files, such as those using the GAEB standard, may also be attached.
- Gross price invoicing: For gross-price invoices issued up to 31 December 2027, issuers may show net totals grouped by VAT rate in the structured data, provided a human-readable attachment contains full line-item details. This temporary arrangement addresses limitations in XRechnung and ZUGFeRD, which lack a gross-price format.
- Rebates and cash discounts: Agreed price reductions must be disclosed on the invoice. If the exact discount amount is unknown when the invoice is issued, a general reference to the written agreement is sufficient, provided supporting documentation can be produced promptly during an audit.
Technical rules, invoice corrections, & compliance
- Business rule errors vs. format errors: A business rule error invalidates an e-invoice for VAT purposes only if it affects mandatory VAT fields. Technical EN 16931 validation errors outside these fields do not prevent input VAT deduction.
- E-invoice corrections: Corrections must also be issued as e-invoices. Reissued invoices, cumulative corrections and commercial credit notes remain acceptable if the final corrected position is clear. Recipient-issued credit notes are also permitted by agreement.
- Mass-market verification: Issuers will not be penalised for failing to issue an e-invoice if they could not reasonably verify, using due commercial care, that the customer was a business. For recurring mass-market customers, such as energy utility clients, verification at contract inception or when the contract changes is sufficient.
- Public sector and penalties: Public fee and tax assessments that serve as invoices may remain in non-electronic formats until 30 June 2030 due to technical constraints. Issuing a paper or PDF invoice instead of a required e-invoice does not constitute an administrative fine offence under § 26a(2) No. 1 UStG.
