On October 15, 2025, Germany’s Federal Ministry of Finance (BMF) released its second official guidance clarifying key aspects of the mandatory B2B e-invoicing regime effective since January 1, 2025. The update amends the VAT Implementation Decree (UStAE) and reflects recent changes to the GoBD (Principles for the Proper Management and Storage of Books and Records in Electronic Form), which were officially revised on July 14, 2025
The new letter differentiates between format errors—technical issues that prevent proper data extraction—and business rule errors, such as incomplete or inconsistent invoice data. It confirms that structured EN 16931-compliant e-invoices do not require a separate human-readable copy, and in hybrid formats like ZUGFeRD, the XML data prevails over the PDF layer.
The GoBD amendments specify that only the structured part of an e-invoice must be archived unless the PDF includes additional tax-relevant data. The updates also reaffirm that credit notes must be issued electronically and stored in their original structured form.
Overall, the updated guidance reinforces Germany’s transition toward fully digital, standardized invoice processes, ensuring consistency and data integrity across accounting and VAT reporting systems.
