Germany began introducing mandatory B2B structured e-invoicing in 2025. In the first phase, businesses must be able to receive e-invoices. The next major phase will start in 2027, when suppliers will be required to issue e-invoices for all in-scope transactions
Germany: Updated BMF Guidance on 2025–2028 B2B E-Invoicing Rollout
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Germany
Author: Ivana Picajkić
Category:
Fiscal subject related
General information
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15365
Content accuracy validation date:
23.10.2025
Content accuracy validation time:
08:25h
Germany began introducing mandatory B2B structured e-invoicing in 2025.
In the first phase, businesses must be able to receive e-invoices.
The next major phase will start in 2027, when suppliers will be required to issue e-invoices for all in-scope transactions.
On 15 October 2025, the Federal Ministry of Finance (BMF) published an updated guidance letter explaining how the three-year rollout will work and clarifying technical and legal details.
Updates in the New BMF Letter:
1. Format errors (Syntax Errors)
An invoice is considered invalid if:
- It does not follow the approved syntaxes (e.g., XRechnung, ZUGFeRD), or
- Mandatory VAT fields cannot be read from the structured data.
Such documents are treated as ordinary electronic files, not as valid e-invoices.
2. Business rule errors (VAT Errors)
Errors that break established business or VAT rules are now clearly defined.
If these errors affect mandatory VAT details, the invoice is invalid.
The definition of a “critical error” has been moved to paragraph 6b of the BMF letter.
3. Invoice validation
Companies may use a validation tool to examine invoices for both format and content errors.
However, the issuer remains legally responsible for ensuring invoice accuracy.
All validation reports must be kept for audit purposes.
Additional clarifications:
- Mandatory data must appear within the structured invoice itself; references to attachments or external links are not compliant.
- Opting for VAT: When VAT is applied voluntarily under Section 9(1) of the VAT Act, e-invoicing is still mandatory.
- Price reductions or complaints that do not alter the actual supply do not require invoice corrections.
- Retention: All incoming and outgoing e-invoices must be kept for eight years.
Here is the link to the BMF letter:
The updated BMF letter strengthens Germany’s phased e-invoicing rollout by defining clear rules for format and content validation, reinforcing taxpayer responsibilities, and emphasising data integrity within structured e-invoice formats.
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