BDO: German Ministry of Finance Issues New E-Invoicing Guidance

Germany's Federal Ministry of Finance (BMF) issued its third guidance on e-invoicing on October 15, 2026. E-invoicing became a mandatory part of German VAT law on January 1, 2025, requiring businesses to submit structured data. This latest guidance supplements previous administrative instructions from 2024 and 2025.

The new directive addresses practical issues concerning service descriptions, advance and final invoices, construction services, discounts, invoice corrections, and technical validation errors. The BMF also provides clarification on potential penalties. The key takeaway for businesses is that the quality of structured invoice data, not just the file format, is paramount.

The BMF specifies the requirements for service descriptions. The structured part of the e-invoice must clearly depict the nature, scope, and content of the service, as well as its location if applicable, to allow for tax assessment. However, not all details must be structured; supplementary information, such as detailed timesheets, can still be transmitted as an embedded attachment.

The ministry has introduced easements for specific scenarios. For invoices pertaining to advance payments, businesses have an extended deadline for technical implementation. Under certain conditions, simplified technical solutions for reporting partial payments received will be accepted until June 30, 2030. Companies should use this transition period to adapt their invoicing and ERP processes to the structured requirements.