On October 15, 2025, the German Ministry of Finance (MoF) published an update to the October 2024 B2B e-invoicing guidelines. The final version incorporates the amendments proposed in the July 2025 draft and provides important clarifications on the scope, technical requirements, and archiving obligations of the German e-invoicing mandate effective since January 2025.
I. Mandate Scope
1. Small Businesses Exempt from Mandate
It is finally confirmed that small businesses (Kleinunternehmer) are excluded from the e-invoicing obligation. These businesses may continue to issue paper invoices even after the e-invoicing requirement becomes effective.
Nonetheless, they must still be able to receive compliant electronic invoices, as the buyer’s consent requirement will be removed.
2. Small-Value Invoices and Passenger Transport Tickets remain outside of the scope
Invoices under €250 and passenger transport tickets remain outside the mandatory e-invoicing scope and may still be issued in paper form. However, the guidance now explicitly allows suppliers to issue compliant e-invoices for these transactions without needing the buyer’s approval.
3. Invoices with both in-scope and out-of-scope items must follow e-invoicing rules
Invoices that contain both in-scope and out-of-scope transactions must be issued in accordance with e-invoicing requirements.
II. Technical Clarifications
1. Format Errors: Structured electronic invoices that fail to meet the EN 16931 semantic standard due to format errors are not considered compliant e-invoices, instead classified as “miscellaneous invoices”.
2. Content Errors: invoices missing mandatory data fields (article 14 UStG) will also not be considered compliant e-invoices. Content errors can impact VAT deduction.
3. Validation explicitly recommended: The MoF recommends the use of validation tools to ensure format and data accuracy. Both issuers and recipients should perform due diligence checks, and taxpayers should retain evidence of these validation activities for compliance purposes.
III. Archiving requirements clarifications
1. Retention Period Changed/Unaltered: E-invoices must be stored for eight years for VAT purposes. The structured XML portion must be retained in its original, unaltered form to ensure legal integrity.
2. Storage outside GoBD compliant data processing systems is explicitly permitted for VAT purposes. This means that taxpayers are not required to use GoBD-compliant document management systems specifically for e-invoices, though such systems have stricter requirements (e.g.: traceability of business transactions and log of any changes)
3. Authenticity and Integrity continue to be mandatory: The authenticity of origin, integrity of content, and legibility of electronic invoices must be guaranteed throughout the storage period. This can be achieved through one of the following methods: Business Audit Trails, EDI exchange following the EU standard, or Qualified Electronic Signature/Seal.
