Germany Updates Its E-Invoicing Regulations:
New BMF Guidance Released (2025)

On October 15, 2025, the German Ministry of Finance (BMF) published an updated guidance on mandatory e-invoicing, refining the initial circular issued in October 2024. The new document clarifies technical and legal details related to Germany’s mandatory e-invoicing regime effective from January 1, 2025. Key updates address format validation, accepted invoice types, exceptions, and data retention rules.

Following the launch of Germany’s mandatory B2B e-invoicing system on January 1, 2025, the Ministry of Finance released a new circular on October 15, 2025. This updated document supplements the previous 2024 version, integrating new clarifications and amendments into the Umsatzsteuer-Anwendungserlass (UStAE) the official VAT application guideline.

The purpose of the update is to ensure consistent implementation across businesses and to resolve technical uncertainties observed during the transition period.

Key Additions in the 2025 BMF Circular

1. Definition of Format and Business Rule Errors:
   Introduces clear differentiation between technical (format) and logical (business rule) errors in e-invoices.
2. Additional Accepted Formats:
   In addition to XRechnung, both ZUGFeRD (v2.0.1 and higher) and EDI formats are now officially recognized.
3. Expanded Scope:
   Transactions under §13b, partially tax-exempt operations, and Gutschrift (self-billed invoices) now fall under the e-invoice obligation.
4. Clarified Exceptions:
   Small invoices (below €250), small business invoices, and travel tickets remain exempt from the requirement.
5. Mandatory XML Structure:
   All required data must appear within the structured XML file; supplementary information in PDFs or links is invalid.
6. Validation Requirement:
   e-Invoices should undergo format and rule validation, and validation reports are recommended to be stored.
7. Retention and Archiving:
   Structured XML versions of e-invoices must be retained for eight years.
8. Invoice Corrections:
   Corrections to erroneous invoices must also be made in the e-invoice format.
9. Internal Control Procedures:
   Businesses must establish internal controls to ensure the integrity of their e-invoices.
10. Transition Period:
    The transition phase will continue until December 31, 2027.

The 2025 BMF guidance transforms e-invoicing in Germany from a mere compliance requirement into a structured, standardized digital process. Businesses are encouraged to align their invoicing systems with EN 16931 and implement robust validation and control mechanisms for long-term compliance.

https://www.bundesfinanzministerium.de/Content/DE/Downloads/BMF_Schreiben/Steuerarten/Umsatzsteuer/…