Fiscal subject related
General information
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.
Other news from Germany
Germany Updates External Tax Audit Rules
Germany
Author: Ema Stamenković
Germany’s new External Audit Regulations aim to modernize tax audits by making them faster, more coordinated and risk-focused, while updating cooperation and group audit rules. Germany’s Federal Cabinet adopted new External Audit Regulations. The new rules will replace the old Tax Audit Ordinance from 2000 and reflect recent changes in German tax procedure law, including the DAC7 Implementat... Read more
Germany Discusses “21–10–0” VAT Reform
Germany
Author: Ivana Picajkić
Germany is reportedly considering a VAT reform from January 1, 2027, which could raise the standard and reduced VAT rates while applying 0% VAT to basic food products. Germany is reportedly considering a major VAT reform that would shift part of the tax burden from income to consumption. Under the proposal, the standard VAT rate would increase from 19% to 21%, while the reduced VAT rate would ris... Read more
Germany Confirms Email can be Used for E-Invoices, but PDF Alone is not Enough
Germany
Author: Ivana Picajkić
Germany allows e-invoices to be sent by email, but the attached invoice must be in a compliant structured format such as XRechnung or ZUGFeRD with XML, while ordinary PDFs, scans, Word/Excel files, or invoice text in the email body do not qualify as legal e-invoices. Germany allows businesses to send e-invoices by email, but only if the invoice is attached in a legally valid structured format. A s... Read more
Germany Introduces New Withdrawal Button for Online Consumer Contracts
Germany
Author: Ivana Picajkić
Germany’s new mandatory withdrawal button will require online B2C businesses to provide consumers with a clear, permanently available electronic way to withdraw from distance contracts from 19 June 2026. Businesses must update websites, apps, platforms, confirmation messages, and internal processes to support clear withdrawal submission, confirmation, and possible partial withdrawal. Germany has f... Read more
Germany Clarifies Rules for Compliant E-Invoices
Germany
Author: Ivana Picajkić
Germany clarified that compliant e-invoices and credit notes must be self-contained, with all mandatory VAT information included in the structured electronic file itself. Businesses should review invoice templates and ERP systems to avoid relying only on PDFs, links, or separate documents for required invoice data. Germany’s Ministry of Finance has updated its e-Invoicing FAQs to clarify tha... Read more
New webinar was uploaded: Recorded Webinar: Are You Audit-Ready? Retail Tax Checks in Germany, France & Italy
Tax audits are increasingly important in European retail due to high transaction volumes and evolving compliance rules. With different fiscal systems in Germany, France, and Italy, understanding audit focus areas is essential. This webinar covers key audit frameworks, differences, and practical compliance insights for retailers. Read more
Subscribe to get access to the latest news, documents, webinars and educations.
Already subscriber? LoginNew event was created: Reminder - Join our free webinar: Are You Audit-Ready? Retail Tax Checks in Germany, France & Italy
Tax audits are becoming an increasingly important part of modern tax systems across Europe, especially in the retail sector where transaction volumes are high and compliance requirements are constantly evolving. With different fiscalization models in place across Germany, France, and Italy, understanding what authorities actually check during tax audits is essential for retailers and software pro... Read more