Germany Updates VAT Special Audit Reports and Notification

On October 21, 2026, Germany’s Federal Ministry of Finance revised two official forms used in VAT special audits. The updated documents introduce clearer language for audit findings and taxpayer notifications while retaining flexible formatting rules. 

Germany’s Federal Ministry of Finance (BMF) issued two official letters on October 21, 2026, announcing revised versions of the USt 7 B and USt 7 D forms, used by Tax Authorities to document and communicate the results of special VAT audits.

The revisions focus on clearer, citizen-friendly language and retain flexibility in how audit reports and notifications can be prepared. Both forms replace versions announced in the BMF letter of July 12, 2019, and must be applied no later than the publication of the respective October 2026 letters in Part I of the Federal Tax Gazette.

These are administrative updates rather than amendments to Germany’s VAT legislation. They do not introduce new VAT obligations, penalties, transaction reporting rules, or technical requirements for POS systems.

The two revised forms serve different purposes within the VAT audit process.

USt 7 B – Report on the VAT Special Audit is the official document used to record the audit findings, relevant business information, and any differences identified in VAT calculations.

The revised report contains three main sections.

Section I, General Information, identifies the business under examination and records its legal structure, branches, accounting methods, submitted documents, previous audits, and any closing discussion.

Section II, Audit Findings, documents the issues identified during the examination. These may concern the VAT treatment of transactions, accounting information, or discrepancies identified by the auditor.

Section III, Summary of Audit Findings, provides a structured comparison of VAT figures across the examined periods. It covers taxable and VAT-exempt transactions, intra-Community acquisitions, reverse-charge transactions, input VAT deductions, and differences between declared and assessed VAT amounts.

USt 7D – Transmission of the Audit Report is the accompanying notification used to send the audit report to the taxpayer.

It identifies the responsible tax authority, taxpayer, and examination concerned. It also informs the taxpayer that the Tax Authority intends to use the audit findings as the basis for taxation.

The notification allows the tax office to specify a date by which the taxpayer should communicate disagreement with the findings. It also explains that legal remedies may be pursued against tax assessment notices issued following the audit.

Both revised templates may be produced in shortened form through administrative IT systems, including only the sections relevant to an individual examination. Deviations are permitted where organizational or technical reasons require them.

For U.S. 7 B, German federal states may also decide whether to include Section III.

The updated UST 7B form contains several notices explaining the consequences of audit findings under existing tax legislation.

It informs taxpayers that transactions or circumstances examined during certain limited VAT special audits may be examined again during a subsequent audit covering the relevant calendar year.

This applies in the circumstances specified in the form, including examinations covering individual VAT advance-return periods or audits with a restricted scope.

The report also instructs businesses to check whether errors identified during the examination occurred in other reporting periods.

Where the applicable legal conditions are met, businesses must correct previously submitted VAT advance returns and annual VAT declarations without delay, provided the relevant tax assessment limitation period has not expired.

Corrections may also be necessary for recapitulative statements relating to the examined or subsequent periods.

The form further explains that potential criminal or administrative penalty consequences arising from audit findings are considered in separate proceedings.

The revised USt 7 D form explains how the Tax Authority communicates its findings and provides taxpayers with an opportunity to respond.

The USt 7 D notification includes a field in which the tax office may specify a response date if the taxpayer disagrees with the findings.

The notification also distinguishes between responding to audit findings and challenging a subsequent tax assessment.

The audit report itself is not a tax assessment notice. Legal remedies against a tax assessment are subject to separate procedural rules and deadlines.

Impact on retailers and POS providers

For retailers, retail chains, hospitality businesses, and other companies subject to German VAT, the revisions mainly concern how VAT audit findings are documented, communicated, and reviewed.

A retailer undergoing an examination may receive the updated UST 7B report together with the UST 7D notification.

For businesses operating multiple stores or using integrated POS and Enterprise Resource Planning (ERP) systems, the practical consideration is whether transaction information can be reconciled with the VAT figures recorded in accounting.

For POS software providers, cash register manufacturers, and retail technology integrators, the announcements introduce no new technical implementation requirements.

What should businesses do?

No POS modifications or new fiscalization procedures are required by the October 21, 2026 announcements. Retailers should remain prepared to reconcile transaction records with VAT declarations, review audit findings, check any response date specified by the Tax Authority, and correct identified errors where existing legislation requires it.

Businesses should also distinguish the opportunity to comment on audit findings from the separate right to challenge a subsequent tax assessment.

From a professional perspective, the revisions should be understood as improvements to administrative communication rather than changes to Germany’s fiscalization framework.

The practical relevance lies in the existing relationship between POS transaction data, accounting records and VAT declarations, particularly when businesses must explain discrepancies identified during an examination.

The principal source is the German Federal Ministry of Finance letter dated October 21, 2026, regarding the publication of form templates Ust 7B and Ust 7D: link

Ivana Picajkic, Medior Legal Consultant at Fiscal Solutions 

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