The Federal Ministry of Finance published new guidance on E‑Rechnung requirements, error handling, transition periods and validation — here's what it means for your business.
From 1 January 2025, all B2B invoices between German taxpayers must be electronic. Recipients cannot refuse and must ensure technical readiness. A transition period until 31 December 2027 allows paper/PDF with consent. After 2027, only structured E-Rechnung will be accepted.
The letter from October 15, 2025, specifies the upcoming implementation of mandatory E-Rechnung starting January 1, 2025. The key points are:
All invoices between German taxpayers (B2B) must be electronic if both parties are located in Germany. This applies analogously to hospitality, agriculture, and banking sectors.
The recipient does not need to provide separate consent; they must ensure technical capability to receive electronic documents. If a company refuses, the supplier is considered to have fulfilled their obligations.
A transition phase until December 31, 2027 allows paper or unstructured electronic invoices (PDF, scan, email) with consent. After 2027, "sonstige Rechnungen" will no longer be accepted.
If a file does not comply with acceptable syntaxes and technical requirements, it is treated as an "other invoice" and does not meet § 14 UStG.
Violations of logical dependencies and validation rules are flagged as "critical errors" but the invoice retains E-Rechnung status.
Important: Format errors demote an invoice to "other electronic document" — requiring recipient consent and potentially losing VAT deduction rights. Business rule errors require correction but the document stays an E-Rechnung.
An electronic invoice must be machine-readable and comply with EN 16931. BMF allows both fully structured and hybrid formats:
Fully structured XML format
Hybrid format — XML data is leading
All mandatory information (§§ 14 and 14a UStG) must be in the structured part. References to attachments are not allowed.
Parties can choose the format and channel. To send "other" electronic invoices (e.g., PDFs), recipient consent is required.
All B2B invoices between German-registered entrepreneurs must be E-Rechnung, regardless of business size.
Other electronic invoices (PDF, email) are allowed, but only with the recipient's consent. After this date, all B2B invoices must be E-Rechnung.
BMF strongly recommends using a validator (Validierungsanwendung) to check electronic invoices. Validation ensures EN 16931 format and business rule compliance and enables machine reading.
Risk: If errors are found, the invoice must be corrected and resent. Non-compliance may result in refusal of input VAT deduction and fines.
Suppliers send all invoices to a dedicated email. The service accepts both structured E-Rechnung (XRechnung, ZUGFeRD) and temporarily allowed PDFs.
The portal automatically checks format and content: acceptable syntaxes, mandatory fields (Buyer Reference, VAT rates, amounts), and consistency. Results are logged with a timestamp.
Valid invoices are sent to the client's ERP system or another destination, saving time on manual checks and data entry.
Invalid invoices are automatically rejected, and an error report is sent to the responsible staff and supplier for timely correction.
Format & business rule compliance — eliminating the risk of receiving invalid documents
Automated distribution of valid and invalid invoices, reducing accounting burden
Auditable log — each invoice timestamped with status, essential for tax audits
Future-ready — supports hybrid and structured formats, works with Peppol, email, and portals
The BMF letter underscores that the era of paper and PDF invoices is coming to an end. Starting in 2025, businesses must issue and accept E-Rechnung, and by 2028 this becomes mandatory for all B2B transactions.
Update processes — prepare ERP systems for structured invoices and designate responsible parties
Choose a reliable validator — check each invoice for format and logic to avoid VAT deduction refusal
Consider the transition period — other electronic documents allowed until 2028, but only with recipient consent
Use Invoice-Portal — transparent, automated processing compliant with BMF requirements
October 15, 2025
Comprehensive guide to mandatory E-Rechnung implementation, validation requirements, and transition timelines for B2B invoices in Germany.
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Receipt channels: An e-mail inbox is sufficient for the legally compliant receipt of electronic invoices. Alternatively, interfaces or portals are also permitted.
In the long term, the transmission channels will be reviewed as part of the VIDA implementation, with more specific requirements being defined if necessary.
Sanctions: From the start of the obligation (2027 or 2028), ‘other invoices’ (e.g. paper or PDF) will no longer be eligible for input tax deduction. Additional penalties for refusing to accept an e-invoice are currently not envisaged. However, if the recipient refuses to accept the e-invoice even though the sender has demonstrably endeavoured to transmit it correctly, the recipient will be in default.
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