- Germany’s Federal Ministry of Finance (BMF) published a second draft letter on June 25, 2025, revising the VAT Implementation Decree (UStAE) and detailing e-invoicing compliance requirements effective from January 1, 2025, while seeking industry feedback.
- Key compliance aspects include that formatting and content errors can invalidate e-invoices, necessitating corrections to be issued in the same format, and validation tools are recommended for adherence to European Norm (EN) 16931.
- The draft outlines exemptions for small invoices and B2C transactions, specifies archiving requirements for e-invoices, and updates terminology related to e-invoicing, with the final version expected in the fourth quarter of 2025.
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Draft of New BMF Letter on E-Invoicing: Key Changes and Validation Emphasis
- Since January 1, 2025, electronic invoices are mandatory for transactions between domestic companies.
- A new draft BMF letter aims to amend and supplement the previous guidelines on electronic invoicing.
- The draft emphasizes the importance of validating electronic invoices.
- The new guidelines will be incorporated into the VAT application decree.
- The draft addresses formal and content errors in electronic invoices.
- Files with format errors that do not meet structured electronic format requirements are considered other electronic invoices.
- Recipients can claim input tax deduction for non-compliant invoices during transition periods until the end of 2026 or 2027.
- Content errors, such as missing mandatory fields, result in the invoice being non-compliant, excluding input tax deduction.
- A reference to an attachment with unstructured mandatory information is insufficient.
- Incoming electronic invoices should be validated against the EN 16931 standard.
- Many invoicing systems can process electronic invoices, but comprehensive validation is often lacking.
- The RSMinvoice Testkit can help verify validation processes.
- There are eased storage requirements for electronic invoices under VAT law.
Source: ebnerstolz.de
- See also
- Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
