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Check the e-invoice:
What the new BMF letter for 2027 clarifies
On October 15, 2026, the Federal Ministry of Finance published a new BMF letter on e-invoicing. It supplements the previous letters from October 2024 and October 2025. In doing so, it clarifies many questions that were open in practice.
The timing is no coincidence: With the E-invoicing obligation In 2027, companies with more than 800,000 euros in previous year sales must comply Issue e-invoices. From then on, the new requirements from the letter also apply.
At its core, it’s a question that affects every accounting department: How do you verify an invoice? E-bill Right? Technically, tax-wise, and what happens if something is not right? We summarize the most important points and show typical cases from the accounting world.
E-invoicing: These transitional periods now apply
As of January 1, 2025, all companies must Receive e-invoices They can. There are statutory transitional periods for issuing permits. The new letter does not change this:
From 01.01.2027: For companies with an annual turnover of more than €800,000, the transition period ends. From then on, they must issue electronic invoices.
From 01.01.2028: The e-invoice is mandatory for all domestic B2B transactions, unless a statutory exception applies. A separate transitional arrangement applies until the end of 2027 for certain EDI processes.
Some new relief measures from the BMF letter are, however, applicable to individual invoice cases:
Until 31.12.2026: E-invoices that comply with the BMF regulations of 2024 and 2025 but do not yet meet all the new requirements will not be challenged. The same applies to the pre-tax deduction. From 2027, the new regulations will be fully applicable.
Until 31.12.2027: Simplified presentation of gross price-based e-invoices is provided in the structured section.
Until 30.06.2030: In final statements, already paid partial amounts can be presented in a simplified manner: as a sum in the structured section, with details in the free-text field or in an embedded attachment. Furthermore, public authorities’ notices regarding fees and contributions can be issued as separate invoices.
Important: These simplifications do not extend the e-invoicing obligation. They only regulate how certain information may be presented. Anyone who only adapts their processes at the end of 2026 has little time to test it.
Checking e-invoices: technical validation and tax review
The most important clarification concerns the examination of detailed electronic invoices. The BMF clearly distinguishes between the technical and tax aspects.
Format error: The file does not conform to the required format. In this case, no e-invoice is provided for tax purposes; instead, a different invoice is provided.
Business rule errors: The file violates a rule of the standard EN 16931, for example in calculations or field content. Technically, it is no longer considered compliant with the standard. This can have consequences, for example if a system cannot automatically process the file. However, it does not automatically lose its status as an e-invoice in terms of taxation.
Content errors: If sales tax-related mandatory information is missing or is incorrect, the legality of the invoice is affected. This can jeopardize the deduction of input tax. A business rule error will only constitute a content error if it concerns a mandatory information.
What does that mean for you? A test report does not automatically show whether a file is technically valid, whether it meets the format requirements, and whether the invoice is correctly VAT-compliant. Therefore, an error message in the validator does not mean that you have to reject the invoice. Conversely, a technically error-free file is not yet an accurately VAT-compliant invoice.
Anyone who wants to check an electronic invoice needs both: technical validation and a review of the mandatory information requirements under §§ 14 and 14a of the German Value Added Tax Act (UStG). The technical verification remains important, because only clean data can be reliably processed automatically.
Typical case: A supplier sends a XRechnung, The validator reports a business rule error in a field that is not mandatory. From a tax perspective, the file remains an electronic invoice. Technically, however, the error can interfere with the automatic processing. It is therefore advisable to provide a warning to the supplier so that the error no longer occurs in the future.
Good to know about ZUGFeRD: The difference from the XInvoice is in the structure. The XInvoice consists only of XML data; a ZUGFeRD invoice additionally includes a PDF. From a tax perspective, the most important factors are: ZUGFeRD The XML data. While PDF and XML are distinct entities, the XML specifications apply. Therefore, a validator only checks the XML part, not the PDF.
Description of the performance: What is included in the data and what is included in the appendix
The performance description must be included in the structured part of the e-invoice, i.e., in the machine-readable data. A reference to a PDF or a contract is not sufficient for this purpose.
Specifically, the type of service, the scope of service, the level of service, and, if applicable, the place of service must be clear enough so that the tax treatment can be derived from them. For example, it must be clear whether it is a delivery or other service, what tax rate applies, and whether the service was provided for the company.
However, not every detail needs to be included in the data. Supplementary information such as time records can be included in an embedded attachment, for example as a PDF.
Typical case: The invoice only states „Consulting in accordance with the contract“ as the service provided. That is not enough. Better: „IT consulting for the implementation of the debtors ledger, September 2026, 24 hours.“ The supporting documents can be attached as an annex.
Relief for special accounting situations
For some types of invoices, the BMF letter clarifies how they work as an e-invoice.
Depository and final calculations: Advance payment and settlement invoices that were submitted before the start of the own e-invoicing obligation do not have to be e-invoices. In the final calculation, amounts already paid up to June 30, 2030 may be shown as a sum in the „Paid amount“ field, with details in the free text field or in an embedded attachment.
Construction works: The performance list does not yet fit technically into the structured part. Therefore, for the time being, the details are presented in a single document. The details must be included in a readable, embedded appendix that clearly references the invoice.
Discounts, Bonuses, Discounts: A general indication of a written agreement is sufficient if the documents can be submitted quickly. If the agreement changes later, the invoice does not need to be corrected.
Gross price: There is no format yet for gross price invoices for XRechnung and ZUGFeRD. Until December 31, 2027, such invoices may only include the amounts per tax rate in the structured part. The individual items will then be included in an embedded appendix.
Invoice correction: The correction must also be an e-invoice
If the obligation to provide an e-invoice exists, it also applies to corrections. Technically, it has not yet been determined which invoice type applies to which type of correction.
The BMF therefore allows for any practical correction for the time being. What is crucial is that the original calculation and the correction together clearly show what is actually applicable.
In addition, the beneficiary of the benefit can also correct or supplement the invoice by prior arrangement by crediting the amount to the original invoice. The crediting must clearly relate to the original invoice.
What does that mean for you? Decide how corrections are made within your organization: Who is responsible for making them, what invoice type is used, and how is the original invoice referenced?
No fine, but risk when deducting the VAT
According to the BMF, if someone issues an invoice other than the prescribed electronic invoice, they do not commit an administrative offense under § 26a UStG. Therefore, no fine is threatened.
That does not mean that the form is irrelevant. The obligation to issue an electronic invoice remains in place. And for the recipient’s tax deduction, the mandatory information must be complete and correct. If it is missing, the invoice must be subsequently completed, and this is fundamentally the responsibility of the invoice issuer.
In the mass market, such as in energy providers, there is an easing of the rules: if the exhibitor did not know that their customer is a company, the violation will not be reported. A clarification at the start of the contract or during a change is sufficient.
Why a validator alone is not enough
The writing confirms what we see in the daily invoice entry: checking an e-invoice means more than sending an XML file through a validator.
Many companies treat every error message the same. Either the invoice is rejected even though it is tax-compliant, or it is booked because the technology gives the green light even though a mandatory field is missing. Both cost time and, in the worst case, tax revenue.
Not every validation error renders an electronic invoice tax-neutral. For stable and automated invoice processes, reliable technical testing is nevertheless crucial. In addition, the tax inspection of the mandatory information and a clear process for inquiries and corrections are essential.
Checklist: How to prepare for the e-invoice obligation in 2027
- Check whether your company will have to issue electronic invoices starting in 2027 or starting in 2028.
- Clarify how you check incoming electronic invoices: technically and tax-wise.
- Determine how to handle format and business rule errors.
- Check your performance descriptions: Are the important details included in the structured data?
- Define a process for invoice corrections and credits.
- Consider special cases: advance payments, construction services, discount agreements, gross prices.
- Play through real invoices from input and output, including attachments and errors.
- Clarify responsibilities between accounting, tax, IT, and service providers.
Conclusion
The new BMF letter does not bring about a revolution, but it does provide important clarity. The message is clear: In e-invoicing, not only format and technology matter, but above all correct content. Anyone who wants to review e-invoices needs both technical validation and professional classification.
There is little time left until the e-invoicing obligation in 2027. Use the remaining weeks to test your processes with real invoices.
Do you want to know how to secure your revenue forecast for 2027? Contact us.
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Note: This article is for general information purposes only and does not replace tax advice.
