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 letterRn. 35a
Correct the invoiceNo
Keep the validation reportRecommended

Validation does not replace checking the invoice for correctness; it supports it (Finance Ministry letter of 15 October 2025, para. 35a).

How this is checked

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

Finance Ministry letter of 15 October 2025, selection.
ParagraphTopicKey statement
6aFormat errorsFile cannot be processed against the schema: not an e-invoice but an ordinary invoice
6bBusiness-rule errorsFile readable, but a rule is broken; effect depends on the detail concerned
17Self-billingThe mandate applies to self-billed invoices too
22Exceptions and consentSmall amounts, small businesses, travel tickets may be ordinary invoices; consent may be tacit
35aValidationDoes 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 2027/2028No
Receipt since 2025Only with your consent
To read itOrdinary software
Classify every format →

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.

Common questions

Which Finance Ministry letter on e-invoicing applies now?

The letter of 15 October 2025 with reference III C 2 - S 7287-a/00019/007/243 is the one to use. It builds on the first letter of October 2024, restates the interpretation and transfers it into the VAT application decree. If you still work with quotes from the 2024 letter, look the paragraphs up in the new text, because some statements have been refined.

What is the difference between a format error and a business-rule error?

A format error exists when the file does not match the format’s schema and cannot be processed; under paragraph 6a it is then not an e-invoice. A business-rule error exists when the file is readable but breaks one of the format’s rules, for example a missing buyer reference. Whether it matters depends on whether a mandatory detail is affected.

Does the e-invoicing mandate apply to self-billing credit notes?

Yes. Paragraph 17 of the ministry letter makes clear that the mandatory e-invoicing rules apply equally when the customer issues the invoice by self-billing (section 14(2) sentence 5 UStG). A customer who bills on behalf of a supplier, for example for commissions, must therefore issue that self-billed invoice as an e-invoice from the known cut-off dates as well.

Must I validate every e-invoice before paying it?

The letter contains no express duty to run a technical validation. Paragraph 35a says that validation does not replace checking the invoice for correctness but supports it. If you want to secure your input VAT deduction, check content and amounts as with any invoice. A pre-check helps, because it shows arithmetic errors and missing fields at once.

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