Germany: What the BMF Letter of 15 October 2026 Changes for B2B e-Invoicing

The new letter

On 15 October 2026 the German Federal Ministry of Finance (BMF) published a further letter on mandatory e-invoicing between businesses in Germany. It adds to the BMF letters of 15 October 2024 and 15 October 2025, was agreed with the tax authorities of the federal states, and writes several of its rules into the VAT Application Decree, the rulebook that tax offices work from. It will be published in the Federal Tax Gazette.

The letter does not change the deadlines. Receiving e-invoices has been compulsory since 1 January 2025. Issuing them becomes compulsory on 1 January 2027 for businesses whose turnover exceeded 800,000 euros in the previous year, and on 1 January 2028 for all other domestic businesses. The letter's rules apply to supplies made after 31 December 2024, subject to the transitional rules running until 31 December 2027. The letter also says its rules will be reviewed, and adjusted where necessary, once the requirements of the planned VAT reporting system are known. The full timeline is on our Germany country page.

Advance, prepayment and instalment invoices

If a business sends an advance, prepayment or instalment invoice before its own obligation to issue e-invoices begins, that invoice does not have to be an e-invoice. This applies even if the goods or services are delivered, and the payment is made, after the obligation has started.

Final invoices

A final invoice has to deduct the payments already received. Until 30 June 2030, the tax authorities will accept two ways of doing this in an e-invoice. The first is to show the payments already received as a single total in the "paid amount" field, with the details in the invoice's free-text note field. The second is to set out the deduction in an attachment embedded in the e-invoice, provided the invoice expressly refers to that attachment.

The second option was previously allowed only until 31 December 2027. It now also runs until 30 June 2030.

Customers who may or may not be businesses

The e-invoicing obligation applies to supplies to other businesses, not to consumers. The letter says a supplier will not be challenged for failing to issue an e-invoice as long as it did not know, and could not have recognised with the care expected of a prudent businessperson, that the customer was a business buying for its business.

Some suppliers have a large customer base of both businesses and consumers on ongoing contracts; the letter gives the example of an energy supplier. For them, checking when the contract starts or changes is enough. Regular checks during the contract are not needed.

Mandatory details in the structured part

The letter distinguishes between the structured part of an e-invoice, which is the data a computer reads, and attachments embedded in it. The details that VAT law requires on any invoice apply to e-invoices as well.

KoSIT and FeRD, the bodies behind the German XRechnung and ZUGFeRD formats, have published a table showing which field of the European e-invoicing standard should hold each required detail. The tax authorities recommend using the current version of that table.

Description of the supply

The structured part has to describe what was supplied clearly enough for the invoice to be checked. In particular, the type, extent and content of the goods or services, and where relevant the place of supply, have to be clear from the structured data alone.

That is what allows the tax office to tell whether goods or services were supplied, where the supply took place and whether the right VAT rate was used. It also shows whether the customer is in principle entitled to reclaim the VAT. Not every detail is needed. Extra information, such as a breakdown of timesheets, can go in an embedded attachment instead.

Construction services

Construction work is often invoiced against a bill of quantities, which the European standard cannot currently carry in its structured data. For now, an e-invoice for construction services can list just the individual trades and their totals in the structured part.

The detailed breakdown by bill of quantities must then be in a readable attachment embedded in the invoice, and the structured part must clearly refer to it. The bill of quantities can also be sent as a separate structured file, for example in the GAEB standard, and the parties can agree another suitable method between themselves.

Discount agreements

Any price reduction agreed in advance, such as a bonus, cash discount or rebate, has to be mentioned on the invoice unless it is already reflected in the price. Where the amount is not yet known when the invoice is issued, the invoice must refer clearly to the agreement.

A general reference to a written agreement is acceptable, as long as the documents can be produced quickly as part of the business's VAT records and checked easily. If the agreement changes after the invoice has been issued, the invoice does not need to be corrected.

Gross-price invoices

The European standard calculates from the price before VAT. Where a price is set including VAT, as with books sold at a fixed retail price, which is the example the letter gives, this can lead to rounding differences. Neither XRechnung nor ZUGFeRD yet offers a format based on gross prices.

For e-invoices of this kind issued up to 31 December 2027, the structured part may therefore show only the totals for each VAT rate or exemption, together with the VAT rate and the VAT amount, or a note of the exemption. The individual items must then appear in a readable attachment embedded in the invoice, which the structured part must clearly refer to.

Corrections

Where an e-invoice is required, a correction to it must also be an e-invoice, using the invoice type intended for corrections. There is no technical rule yet on which invoice type to use for common practices such as replacing an invoice, a cumulative correction or a commercial credit note.

What matters for tax purposes is that the original invoice and its corrections, read together, make the final details clear. On that basis, any workable method of correction can currently be sent as an e-invoice. The customer can also correct an e-invoice by issuing a credit note, provided this has been agreed in advance and the credit note refers clearly to the original invoice.

Business-rule errors

The European standard includes technical checks, called business rules, that test whether the information in an invoice fits together. From a technical point of view, an invoice that fails any of them no longer meets the standard. The letter says that technical view does not decide the VAT position.

For VAT purposes, an invoice with a business-rule error, but in the correct format, is in principle still an e-invoice. The error only matters for VAT where it affects one of the details VAT law requires. To count as a proper invoice, the e-invoice must still contain all of those details, correctly and in full.

Invoices to the public sector

Invoices to public bodies fall under the VAT e-invoicing rules only where the public body is acting as a business. Separately, suppliers have had to invoice federal contracting authorities electronically under the federal e-invoicing regulation (E-Rechnungsverordnung) since 27 November 2020.

Neither set of rules overrides the other, and each applies within its own scope. Where one allows a choice that the other rules out in practice, for example because of different thresholds or transmission routes, the stricter rule applies.

Assessments of public-law charges

When a public body charges a fee, contribution or reimbursement of costs for something it supplies, the official notice can also count as a VAT invoice. In that case, subject to the other conditions, it must be issued as an e-invoice.

Because of current technical limits, the tax authorities will accept notices issued up to 30 June 2030 in another invoice format. Where a separate VAT invoice is issued alongside the notice, the VAT must not be shown on both, or the extra amount becomes payable as incorrectly shown tax.

Fines

Where a business has to issue an e-invoice and sends a different kind of invoice instead, this is not an administrative offence under the fine rule for failing to issue an invoice. The other consequences of a missing e-invoice, including for the customer's right to reclaim VAT, are set out on our Germany country page.

Transition

E-invoices issued up to 31 December 2026 that follow the October 2024 and October 2025 letters, but not the additional rules in this one, will not be challenged, including when the customer reclaims the VAT.

Further reading

Our Germany country page sets out the full mandate, with the timeline, exemptions, penalties and official sources. For formats, deadlines and requirements in one place, see our Germany e-invoicing guide. The 2027 deadline article covers the earlier BMF letters and the transitional rules.