Germany's BMF letter of 15 October 2026: what changed

On 15 October 2026 Germany's Federal Ministry of Finance (BMF) published a third letter on mandatory B2B e-invoicing (ref. III C 5 - S 7287-a/00019/021/017). It supplements the letters of 15 October 2024 and 15 October 2025. Below are its points with their paragraph numbers (Rn.), in plain English. As of 22 October 2026; this is our summary, not tax advice.

Down payments and final invoices

• Down-payment and interim invoices issued before your own e-invoicing obligation starts don't have to be e-invoices, even if delivery and payment come later (Rn. 2).
• Until 30 June 2030, a final e-invoice may deduct the payments already received as one total in BT-113 (Paid amount), with the details in the free-text note BT-22 (Rn. 3). Alternatively in an embedded attachment referenced in the structured part; this option now also runs until 30 June 2030 instead of the end of 2027 (Rn. 4).

Business or private customer?

If you didn't know, and couldn't reasonably have known, that the customer was a business, missing the e-invoice obligation is not objected to (Rn. 5). In mass business with ongoing contracts (e.g. energy suppliers), checking at the start or change of the contract is enough (Rn. 6).

Mandatory details and line descriptions

• For mapping the VAT-mandatory details to EN 16931 business terms, the tax authorities recommend the KoSIT/FeRD mapping table (Rn. 8, 9).
• Type, quantity, content and, where relevant, place of the supply must be in the structured part, clearly enough to check the VAT rate, place of supply and input-VAT deduction. Further detail such as timesheets may go into an embedded attachment (Rn. 10 to 12).
• Construction work: the structured part may list only the trades with totals, if the detailed bill of quantities is embedded as a readable attachment and referenced (Rn. 13, 14).
• Bonuses, discounts and rebates: a general reference to a written agreement is enough if the documents can be produced quickly; if the agreement changes later, the invoice doesn't need correcting (Rn. 15, 16).

Invoices based on gross prices

EN 16931 calculates from net amounts, which can cause rounding differences for gross-price sales such as books with fixed retail prices (Rn. 18). XRechnung and ZUGFeRD have no gross-price format yet, so until 31 December 2027 it is accepted if the structured part only contains the totals per VAT rate with the VAT amounts, and the individual lines are in an embedded readable attachment that is referenced (Rn. 19).

Corrections

Where an e-invoice is mandatory, its correction must be an e-invoice too. Which invoice type code to use for replacing or cumulative corrections and commercial credit notes is not yet technically defined; for now any workable method is accepted as long as the original and the corrections together clearly show the final invoice details (Rn. 20, 21).

Validation errors and VAT

Breaking a business rule (for example BR-CO-10) is not a format error for VAT purposes but a business-rule error; it only becomes a content error if it affects a VAT-mandatory detail (Rn. 22). Technically such a file no longer conforms to EN 16931, but for VAT it is in principle still an e-invoice within § 14 UStG, provided the mandatory details are correct and complete (Rn. 23). It is still worth fixing, since receiving software often checks these rules automatically. You can check any file with our free validator.

Public sector and fee notices

Invoices to public authorities fall under the VAT e-invoicing rules only when the authority acts as a business; public-procurement rules such as the federal E-Invoicing Ordinance (since 27 November 2020) apply alongside, and the stricter rule wins (Rn. 24, 25). Notices for public fees that are also invoices may be issued as other invoices until 30 June 2030 (Rn. 27).

No fines, transition to end of 2026

Issuing an other (non-e-)invoice where an e-invoice was required is not an administrative offence under § 26a(2) no. 1 UStG (Rn. 28). E-invoices issued until 31 December 2026 that follow the 2024 and 2025 letters but not the new requirements are not objected to, including for input-VAT deduction.

Source

BMF letter of 15 October 2026 (PDF, German, bundesfinanzministerium.de). German version of this summary: BMF-Schreiben vom 15.10.2026.