Summary
- Germany’s Ministry of Finance has issued supplementary guidance on mandatory domestic B2B e-invoicing, complementing its letters of 15 October 2024 and 15 October 2025.
- A failure to issue an e-invoice will not be challenged if the issuer neither knew nor should have known that the customer was a business acting as such; corrections must themselves be e-invoices using a correction invoice type.
- The authorities recommend the KoSIT/FeRD mapping table for EN 16931 fields, and e-invoices issued by 31 December 2026 that meet earlier guidance will not be challenged, including for input VAT deduction.
Extended article
No technical specification yet determines which invoice type must be used for replacement corrections, cumulative corrections or commercial credit notes. For tax purposes, the decisive test is whether the final invoice particulars are clear and unambiguous when the original and correction invoices are read together; any workable correction method may currently be transmitted using a suitable invoice type.
Issuing an invoice in another form where an e-invoice was required does not constitute an administrative offence under Section 26a(2), point 1, of the VAT Act. The principles apply to transactions after 31 December 2024, subject to the transitional rules until 31 December 2027, and will be reviewed once future reporting-system requirements are known.
Source
- German Federal Ministry of Finance: Guidance of 15 October 2026 (German)
- XEinkauf: XRechnung Standard
