Sur 15 October 2026, the German Federal Ministry of Finance (BMF) issued additional guidance on German e-invoicing, clarifying technical requirements, invoicing scenarios and transitional tolerances. It comes ahead of the next phase of the domestic B2B e-invoicing mandate, which starts on 1er janvier 2027 for businesses with prior-year turnover above EUR 800,000, subject to the applicable statutory exceptions and transitional rules.
The letter confirms that a business-rule validation error does not automatically make an e-invoice incorrect for VAT purposes. The VAT consequences depend on whether the error affects mandatory VAT information. The BMF also recommends the KoSIT and FeRD mapping tables for locating mandatory tax information within the structured invoice data.
The guidance sets out relief for specific scenarios. Construction invoices can summarise trades in the structured data and attach the full service details. Until 30 June 2030, final invoices may deduct advance payments as a total in BT-113, with the required payment details in BT-22. Alternatively, an embedded attachment may provide those details where the structured invoice explicitly refers to it. Gross-price rounding summaries are allowed until 31 December 2027.
Corrections generally need to use a structured format, while the guidance retains flexibility in how corrections are made. There is currently no fine specifically for failing to meet EN 16931 requirements. However, invoice defects can still affect tax audits and input VAT deduction.
Source : German Federal Ministry of Finance (BMF), letter of 15 October 2026.
For the implementation context, see our guide to Germany’s B2B e-invoicing mandate and explore SAP e-invoicing integration.