The BMF letter of 15 October 2026 clarifies the VAT treatment of business-rule errors, specifies the information required in structured invoice data and extends two administrative relief arrangements to 30 June 2030.
The German Federal Ministry of Finance (BMF) published a further letter on electronic invoicing on 15 October 2026. It supplements the letter of 15 October 2024 introducing the rules and the letter of 15 October 2025 amending the German VAT Application Decree (UStAE). The new letter, reference III C 5 - S 7287-a/00019/021/017, comprises ten pages.
Paragraphs 22 and 23 clarify that an invoice file with a business-rule error may still qualify as an e-invoice for VAT purposes. Technical non-conformity alone does not determine entitlement to deduct input VAT. An unsuccessful validation result therefore does not automatically establish that an invoice is defective for VAT purposes. The letter also specifies the information required in the structured part of an invoice and extends two administrative relief arrangements to 2030.
The 2025 letter defines a format error in paragraph 6a and a business-rule error in paragraph 6b. Paragraphs 22 and 23 of the new letter clarify the VAT consequences and distinguish between technical conformity and VAT compliance.
A violation of a business rule in the core invoice model means that the file does not conform to the EN 16931 series. This also applies when the affected information is not mandatory for VAT purposes. From a technical perspective, the file is therefore not a conformant e-invoice.
Provided it has no format error, the same file may still qualify as an e-invoice under section 14 of the German VAT Act (UStG). A business-rule error results in a VAT-relevant content error only when it concerns information required for VAT purposes.
The letter states that the technical assessment does not determine the VAT treatment, including entitlement to deduct input VAT.
Technical validation and VAT compliance require separate assessment. An unsuccessful validation result does not automatically make an invoice defective for VAT purposes. Conversely, successful validation alone does not establish VAT compliance. Under paragraph 23, the mandatory information required by sections 14 and 14a UStG must be correct and complete.
The new sentence 3 in section 14.5(15) UStAE specifies the requirements for describing the supply. The structured invoice data must identify the type, scope and substance of the supply and, where relevant, the place of supply, sufficiently clearly to:
distinguish a supply of goods from a supply of services,
determine the place of supply,
check the VAT rate applied,
and assess the entitlement in principle to deduct input VAT.
These details enable the tax authorities to identify the supply and assess its VAT treatment. A reference to a contract alone does not fulfil this requirement. Paragraph 11 also states that the services do not need to be described exhaustively. The necessary level of detail depends on the circumstances of the individual case.
Supplementary information that is not necessary for this VAT assessment may be provided in an embedded attachment. Paragraph 12 gives a detailed breakdown of timesheets as an example; the amendment to section 14.5(15) UStAE refers to a PDF file. The information required to assess the VAT treatment must remain in the structured invoice data.
Paragraphs 8 and 9 recommend using the current mapping table prepared by KoSIT and FeRD to assign mandatory VAT information to Business Terms (BT) and Business Groups (BG) under EN 16931-1. Links to both organisations’ publications appear in the sources below.
The letter replaces the wording contained with embedded in four provisions of the VAT Application Decree: section 14.1(17), sentence 5; section 14.1(19), sentence 1; section 14.5(9), sentence 5; and section 14.5(17), sentence 4. The revised wording on supplementary information in section 14.5(15) also refers to an embedded attachment.
These provisions address the inclusion of the underlying contract. For recurring contractual arrangements, such as leases, maintenance contracts or fixed-fee arrangements with a tax adviser, a single e-invoice for the first partial supply period may suffice where the relevant conditions are met and the contract is embedded in the invoice file. Other provisions concern contracts that serve as invoices but do not meet the required e-invoice format; these require an additional correcting e-invoice.
The revised wording clarifies the existing requirement. A reference in the structured data to a separate unstructured annex is insufficient. An external link likewise does not fulfil the requirements of section 14(1), sentence 3 UStG or section 31(1) of the German VAT Implementing Regulation (UStDV). Describing the document as an embedded attachment makes clear that sending a separate file with the invoice is insufficient.
The letter provides several arrangements under which the tax authorities will not object to specified invoicing practices. Two apply until 30 June 2030. Their conditions and deadlines should be considered in implementation planning.
Until 30 June 2030, paragraph 3 permits advance payments already received to be deducted as a total in BT-113 (Paid amount), with the required details provided in BT-22 (Invoice note). Paragraph 4 permits an alternative: the deduction may be set out in an embedded, unstructured attachment meeting section 14.8(8), point 2 UStAE, provided the structured invoice data expressly refer to it. This second method was already permitted by paragraph 48 of the 2024 letter until 31 December 2027. The new letter extends that arrangement to 30 June 2030.
Paragraph 18 explains that the EN 16931 core invoice model calculates from the amount excluding VAT. Where a price is fixed inclusive of VAT, this can cause rounding differences; the letter gives a book subject to fixed book pricing as an example. In such cases, the letter suggests using an admissible e-invoice format based on gross-price calculation. Whether such a format is used, and which one, is a matter for the contracting parties under civil law.
Paragraph 19 states that a gross-price invoice format is not yet available for XRechnung or ZUGFeRD. For e-invoices based on gross prices and issued by 31 December 2027, the structured data may therefore contain only the totals broken down by VAT rate and exemption, together with the applicable rate and VAT amount or exemption reference. An embedded, human-readable attachment must contain a proper description of the supply and its line items. The structured totals must be derivable from that attachment, which must be referenced unambiguously in the structured data.
Where a bonus, early payment discount or rebate has been agreed but its amount is not yet known when the invoice is issued, the invoice must refer unambiguously to the agreement. Paragraph 16 and the new sentences 6 and 7 in section 14.5(19) UStAE permit a general reference to a written agreement, provided the supporting documents form part of the records under section 22 UStG, can be produced promptly and can be checked easily and unambiguously. A subsequent change to the agreement does not require the invoice to be corrected.
The letter identifies technical limitations that prevent a full schedule of works (Leistungsverzeichnis) from being represented in the structured part of an invoice using the core data model. It therefore permits the structured description to list the individual trades and their totals, provided an embedded, human-readable attachment contains the detailed schedule and is clearly referenced in the structured data. The schedule may additionally be transmitted as a structured file, for example using the GAEB standard. The contracting parties may agree another suitable method under civil law, such as an extension that includes the schedule in the structured invoice data.
The letter does not prescribe a final technical mapping for correction types. Paragraph 20 confirms that, where an e-invoice is required, a correction under section 31(5) UStDV must also be issued as an e-invoice using a suitable correction type. It also states that the technical representation of three common correction methods has not yet been determined: a replacement correction, a cumulative correction and a commercial credit note.
Under paragraph 21, the original invoice and any corrections must together make the final invoice information clear and unambiguous. Subject to that condition, a correction method suitable for the transaction may currently be used with an appropriate invoice type.
The new sentence 7 in section 14.11(2) UStAE also permits the recipient to correct or supplement an e-invoice by issuing a self-billed invoice (Gutschrift). This requires prior agreement and a specific, unambiguous reference to the original invoice. Self-billing in this VAT context is distinct from a supplier-issued commercial credit note.
Paragraph 28 states that issuing an invoice in another form when an e-invoice is required does not constitute an administrative offence under section 26a(2), point 1 UStG. This statement concerns that specific provision.
The revised section 15.11(3) UStAE specifies the conditions for deducting input VAT. Under sentence 2, an invoice that does not fully contain the information required by section 14(4), sentence 1, points 1 to 8 and 10 UStG must generally be completed before it supports input VAT deduction. Completion is generally carried out by the issuer. Sentence 6 limits the use of other business records, such as a delivery note, to prove the quantity supplied or the date of supply to invoices in other forms. This evidential option is not provided for e-invoices.
The principles apply subject to the statutory transition arrangements running until 31 December 2027. The letter refers to paragraphs 62 to 65 of the 2024 letter. For earlier supplies, the version of the VAT Application Decree in force on 31 December 2024 applies.
The tax authorities will not object, including for input VAT deduction, if an e-invoice issued by this date meets the requirements of the 2024 and 2025 letters but not the additional requirements introduced by the 2026 letter. Implementation planning should therefore take account of this year-end deadline.
The final statutory transition arrangements and the administrative relief for gross-price invoices end on the same date. Businesses using gross-price invoicing should account for both deadlines in their implementation plans.
The arrangements for final invoices deducting advance payments and for public-law assessment notices issued as invoices in other forms end on this date. Paragraph 1 states that the rules will be reviewed and, if necessary, adjusted in light of the reporting system requirements applicable at that time.
Distinguish between format errors, business-rule errors without a VAT-relevant content error, and business-rule errors affecting mandatory VAT information. An undifferentiated error message does not provide a sufficient basis for assessing the consequences.
Check whether the structured data adequately describe the type, scope and substance of the supply and, where relevant, its place. A description such as services as per contract may pass technical validation while failing to provide the information needed for the VAT assessment.
Where a contract is required as part of the invoice documentation for a recurring arrangement, check that it is embedded in the invoice file. A separate email attachment or an external link is insufficient.
Choose between BT-113 with BT-22 and an embedded attachment expressly referenced in the structured invoice data. Both methods are permitted under the stated conditions until 30 June 2030.
The tax authorities recommend the current mapping table. Use it to review how mandatory VAT information is assigned to the invoice’s structured data fields.
The technical implementation should address two requirements: the structured invoice data must contain the information needed to assess the VAT treatment, and supporting documents must be embedded where required. Both should be considered when configuring invoice generation.
We convert invoice data from your ERP system into XRechnung, ZUGFeRD or Peppol BIS Billing, embed attachments in the invoice file and validate the document before dispatch. This allows identified business-rule errors to be reviewed before transmission to the recipient. You can also use our free E-Invoice Validator in your browser to check the technical conformity of invoice files.
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