On October 15, 2026, the German Federal Ministry of Finance (BMF) issued a letter that supplements its e-invoicing guidance of October 15, 2024, and October 15, 2025. The letter also amends the VAT Application Decree (Umsatzsteuer-Anwendungserlass, UStAE). The BMF plans to review the rules when the requirements of the future reporting system* are known.
According to this new guidance, advance, down payment, and installment invoices issued before an issuer’s e-invoicing obligation starts do not need to be e-invoices. This applies even if the supply and payment happen later.
The letter introduces several tolerance rules that the tax authorities do not object to:
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Final invoices: Until June 30, 2030, partial payments can be deducted as a single sum in field BT-113 (Paid amount), with details in BT-22 (Invoice note). An embedded unstructured attachment can carry those details instead.
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Construction services: The structured part can list only the individual trades with their totals. An embedded, human-readable attachment must contain the full breakdown, and the structured part must refer to it.
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Gross-price invoices: For invoices issued until December 31, 2027, the structured part can show only totals per tax rate or exemption. The embedded attachment must contain the itemized description.
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Discount agreements: An invoice can refer to a written agreement in general terms if the supporting documents are readily available.
The letter also states that corrections of an e-invoice must be issued as e-invoices. A file with a business rule error but no format error remains an e-invoice for VAT purposes, if it correctly contains the mandatory details. Issuing another type of invoice instead of an e-invoice is not an administrative offense under section 26a(2) no. 1 of the German VAT Act (Umsatzsteuergesetz, UStG).
The principles apply to supplies made after December 31, 2024, with the transitional rules through December 31, 2027. E-invoices issued by December 31, 2026 that meet the 2024 and 2025 letters but not the new requirements are not objected to, including for input VAT deduction.
*Please refer to our previous article on more details on the future introduction of a VAT reporting system.
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