Germany’s Finance Ministry Issues E-Invoicing Clarifications
The German Federal Ministry of Finance (BMF) has published its second official letter of guidance, dated October 15, 2025, providing crucial details for the country's mandatory B2B e-invoicing system. This new guidance, which amends the VAT Implementation Decree (UStAE), offers important clarifications for businesses navigating the transition.
Key Updates and Clarifications BMF
1. Error Types Defined: The BMF now distinguishes between two types of errors:
- Format Errors: These occur when an invoice fails to meet the technical syntax requirements of EN 16931.
- Business Rule Errors: These are logical errors within a technically valid file, such as incomplete information or internal inconsistencies.
2. Hybrid Formats (e.g., ZUGFeRD): For invoices that include both a structured data file (XML) and a human-readable image (PDF), the structured data part always takes precedence in case of any discrepancies. For purely structured e-invoices, a separate human-readable copy is optional.
3. Recipient Obligations: While validation software can check an invoice's technical compliance, the BMF stresses that this does not replace the recipient's responsibility to verify the invoice for business and tax accuracy (e.g., checking for the correct VAT rate).
4. Right to Send E-Invoices: The guidance confirms that invoice issuers can choose their preferred distribution method (like email or EDI). Critically, recipients must be able to receive e-invoices and cannot insist on receiving a paper or "other" invoice format instead.
5. Credit Notes and Archiving: Any correction to an e-invoice, including a credit note, must also be issued as a compliant e-invoice. Furthermore, e-invoices must be archived in their original structured format to ensure data integrity, in line with the recently updated GoBD principles.
There’s more you should know about e-invoicing in Germany – learn more about the new and upcoming regulations.
