Finance Ministry letters on e-invoicing: what the administration decided
Choose what the check reports: the tool shows how the ministry letter classifies the error, which paragraph applies and whether you need to correct the invoice.
For VAT purposes the file is
Proper
A business-rule breach unrelated to sections 14(4) and 14a UStG does no harm.
| Paragraph in the ministry letter | Rn. 35a |
| Correct the invoice | No |
| Keep the validation report | Recommended |
Validation does not replace checking the invoice for correctness; it supports it (Finance Ministry letter of 15 October 2025, para. 35a).
Prepared by Radif Partners · Method · VAT Act, ministry letters and XRechnung 3.0.2 checked on 25 October 2026
The German Federal Ministry of Finance (BMF) has interpreted the e-invoicing mandate in two letters, dated 15 October 2024 and 15 October 2025, the latter with reference III C 2 - S 7287-a/00019/007/243. The second letter restates the interpretation and adds it to the VAT application decree. Four points matter most in practice. First, how errors are classified: a file with format errors is not an e-invoice but an ordinary invoice (paragraph 6a), and breaches of business rules only matter if they concern a mandatory detail (paragraphs 6b and 35a). Second, receiving: an email inbox is enough, and an e-invoice may not be refused. Third, consent to ordinary invoices, which may also be given tacitly (paragraph 22). Fourth, formats: XRechnung and ZUGFeRD from version 2.0.1 are e-invoices, but the ZUGFeRD profiles MINIMUM and BASIC WL are not. The letters bind the tax administration, not the courts, so they are an interpretation rather than law.
Two letters, one line
The law covers e-invoicing in a few sentences of section 14 UStG and the transitional rule in section 27(38) UStG. What those sentences mean day to day was set out by the Federal Ministry of Finance in letters to the state tax authorities. The first is dated 15 October 2024, the second 15 October 2025 (reference III C 2 - S 7287-a/00019/007/243). The 2025 letter is the current one; it transfers the interpretation into the VAT application decree that tax offices apply.
Such letters bind the administration. For businesses they are still the main point of reference, because tax audits follow them. Courts may decide otherwise; there is hardly any case law on the mandate yet, since the duty to issue only begins in 2027.
The paragraphs you should know
| Paragraph | Topic | Key statement |
|---|---|---|
| 6a | Format errors | File cannot be processed against the schema: not an e-invoice but an ordinary invoice |
| 6b | Business-rule errors | File readable, but a rule is broken; effect depends on the detail concerned |
| 17 | Self-billing | The mandate applies to self-billed invoices too |
| 22 | Exceptions and consent | Small amounts, small businesses, travel tickets may be ordinary invoices; consent may be tacit |
| 35a | Validation | Does not replace checking content; rule errors unrelated to mandatory details are irrelevant |
Paragraphs 6a, 6b and 35a belong together. They translate the messages of a technical check into VAT consequences. A checking program such as the KoSIT validator separates schema errors, which prevent reading, from Schematron rules, which test individual content. The ministry draws exactly the same line.
What the error classes mean for input VAT
Under paragraph 6a a file with a format error is merely an invoice in another electronic format. Where the e-invoice is mandatory, the correct form is then missing. For this case the letter added sentences 12 and 13 to section 15.2a(1a) of the application decree: input VAT from such an ordinary invoice generally remains deductible if its content is right. The customer may still demand the correct e-invoice.
A business-rule error needs a closer look. If it concerns a mandatory detail under section 14(4) UStG, such as a VAT amount that does not match the rate, the invoice is not proper and must be corrected. If it concerns a detail required only by the format, such as the buyer reference BT-10 of an XRechnung, it is irrelevant for VAT under paragraph 35a. The tool above classifies your check message; whether a file counts as an e-invoice at all is shown by this calculator:
E-invoice under section 14 UStG?
E-invoice under section 14 UStG?
No
| Usable for domestic B2B from 2027/2028 | No |
| Receipt since 2025 | Only with your consent |
| To read it | Ordinary software |
Receiving, formats and EDI
On receiving, the ministry confirms that an email inbox is enough and that a business may not reject an e-invoice; the ministry’s FAQ repeats this. XRechnung and ZUGFeRD from version 2.0.1 count as e-invoices, except the MINIMUM and BASIC WL profiles, which do not hold a complete invoice. More on ZUGFeRD and what is an e-invoice?.
Structured formats that depart from EN 16931 also remain allowed, such as EDI procedures under Article 2 of Commission Recommendation 94/820/EC, provided the data can be converted correctly and completely into a compliant format. The transitional rule for existing EDI set-ups ends in late 2027; details on EDI invoicing.
Retention under the GoBD
For retention, VAT law relies on the German principles for electronic bookkeeping (GoBD). Their amendment of 14 July 2025 makes clear that for an e-invoice the structured file must be kept, and the visual part of a ZUGFeRD invoice only if it carries tax-relevant additions. The period is 8 years. What that means in practice is explained on archiving e-invoices, and the consequences of faulty invoices on consequences and fines.