BMF Letter of 15 October 2026 Adds Supplementary Rules for the Mandatory E-Invoice and Extends the Final-Invoice Relief to 30 June 2030

KGT Country Update  |  Germany  |  23 October 2026

On 15 October 2026 the German Federal Ministry of Finance (Bundesministerium der Finanzen, BMF) issued a third supplementary letter on the mandatory electronic invoice (E-Rechnung), amending the VAT Application Decree (UStAE) and clarifying how structured invoices must be built before the main issuance obligation starts on 1 January 2027. The letter operates within the existing legal framework, but it sets the interpretation that tax auditors and recipients will apply in practice. 

Background

Germany introduced mandatory B2B e-invoicing on 1 January 2025: all businesses must be able to receive structured invoices conforming to EN 16931, while issuance follows a transition under section 27(38) UStG. Invoices for supplies up to 31 December 2026 may still be issued as other invoices (paper or PDF), and businesses with 2026 total turnover not above EUR 800,000 may continue until 31 December 2027. The BMF has addressed the topic in letters dated 15 October 2024 and 15 October 2025; the new letter is the third published one.

The Legislative Change

This is administrative guidance, not new legislation. The letter amends the UStAE and supplements the 2024 and 2025 letters. It does not change the UStG or the UStDV. It is nonetheless binding on the tax administration and therefore decisive for input VAT deduction, audits and invoice corrections.

Scope

• Structured content: All mandatory invoice particulars (section 14(4) UStG, and section 14a UStG where applicable) must be contained in the structured part of the e-invoice. Mapping follows the KoSIT/FeRD mapping tables; a mere reference to annexes is not enough, and the service description must allow identification of the service and its tax treatment.

• Final invoices after prepayments: Prior partial payments may be shown as a total in BT-113 (Paid amount) with details in BT-22 (Invoice note), or in an embedded annex referenced in the structured part. This relief now runs until 30 June 2030; the 2024 letter allowed the annex route only until 31 December 2027.

• Construction services: The structured part may list trades with totals, provided a human-readable embedded annex with the detailed breakdown is clearly referenced. A structured file such as GAEB may be added.

• Discounts and gross prices: A general reference to a written discount agreement is accepted if documents can be produced promptly. For gross-price invoices issued up to 31 December 2027, totals per tax rate suffice in the structured part with line items in an embedded annex.

• Corrections: Corrections of an E-Rechnung must themselves be electronic; striking through is not permitted. A recipient credit note is possible where agreed beforehand and clearly referencing the original.

• Validation errors: A business-rule error without a format error does not by itself make the file an incorrect e-invoice for VAT purposes; only errors affecting mandatory VAT information have consequences.

• Sanctions and recipient status: Issuing an other invoice instead of a required E-Rechnung is not an administrative offence under section 26a(2) no. 1 UStG. No objection where the issuer neither knew nor, with ordinary care, could have known that the recipient is a business. Public-law fee notices that also serve as invoices may remain other invoices until 30 June 2030.

• Non-objection: E-invoices issued up to 31 December 2026 that follow the 2024 and 2025 letters are not objected to, including for input VAT deduction, even where they miss this letter’s additional requirements.

Timeline

• 15 October 2026: BMF letter issued (reference III C 5 - S 7287-a/00019/021/017, as reported by two independent summaries).

• 31 December 2026: End of the general transition for issuing other invoices; non-objection cut-off for e-invoices following earlier letters.

• 1 January 2027: Issuance obligation applies for businesses above the turnover threshold.

• 31 December 2027: End of transition for businesses with 2026 turnover up to EUR 800,000; end of gross-price totals relief.

• 30 June 2030: End of BT-113/BT-22 final-invoice relief and of the public-law notice relief.

Businesses Affected

All VAT-registered businesses issuing or receiving domestic B2B invoices in Germany, in particular construction, energy, utilities and project-based sectors that use prepayment, final and discount-based invoicing, and multinationals running German invoicing from SAP.

Required Actions

• Confirm that invoice templates populate all mandatory VAT particulars in the structured XML, not only in a PDF or attachment.

• Review prepayment and final-invoice logic for BT-113 and BT-22 and embedded-annex handling.

• Define the correction process (electronic corrections, credit-note arrangements) and a recipient-status check for mass business.

• Align validation rules with the KoSIT/FeRD mapping tables and document how business-rule errors are handled.

Practical Implications

The longer final-invoice relief reduces short-term build pressure for SAP landscapes, but the principle that tax-relevant content sits in the structured part is now explicit. Embedded annexes remain permitted only as supporting detail. Teams should expect auditors to test mapping completeness, not file validity alone.

Expected Next Steps

Watch for the final text on the BMF site and its BStBl publication, the final XRechnung version aligned with EN 16931-1:2026, and further guidance on the electronic reporting planned for 2030.

How Can KGT Support You?

KGT offers SAP-integrated e-invoicing add-ons and SAP Document and Reporting Compliance (DRC) services covering German XRechnung and ZUGFeRD output, mapping reviews, correction scenarios and testing. Contact KGT to assess your readiness for 1 January 2027.

This update is for information only and is not tax or legal advice. Please consult your tax adviser before acting on it.