Statement by the User Association eurofactura – Association for the Promotion of E-Invoicing in Europe e.V.

Subject	BMF letter dated October 15, 2026 – supplementary rules on the introduction of mandatory electronic invoicing for transactions between domestic businesses
Reference	German Federal Ministry of Finance, Division III C 5, GZ III C 5 – S 7287-a/00019/021/017, DOK COO.7005.100.3.15923106
Date	Bielefeld, October 16, 2026

Addressee: German Federal Ministry of Finance, Subdepartment III C, Division III C 5, 11016 Berlin.

 

1. General Position

eurofactura e.V. welcomes the clarifications and simplifications in the letter – in particular regarding discount agreements, the transitional solutions for final invoices and gross price invoices, and the explanation of the VAT consequences of business rule violations.

As a non-profit association of users and experts, eurofactura advocates open, interoperable, and practical e-invoicing processes – across industries and providers. We represent invoice issuers and recipients alike, across the entire invoicing process. Our goal: both sides should be able to reap the full benefits of e-invoicing, from automated data processing to automated verification and posting. This requires legal certainty in VAT matters and machine readability to go hand in hand. That is precisely what our recommendations aim for: practical application by the tax administration and early involvement of users in future changes.

 

2. Consolidated Administrative Guidance and Involvement in the Reporting System

Re marginal no. 1 and the application and non-objection rules

Users have to consolidate the requirements of three BMF letters and the amendments to the German VAT Application Decree (UStAE), each with different deadlines. In addition, marginal no. 1 announces a later review with regard to the reporting system. Businesses need early guidance on which processes will remain in place and which adjustments are to be expected.

Recommendations from eurofactura e.V.

We request that the applicable administrative rules be combined into a consolidated version and that an overview of the application and non-objection rules be published, setting out the conditions, the relevant point in time, the end date, and the consequences for input VAT deduction.

We request the early publication of an implementation plan for ViDA and the planned reporting system, as well as the systematic involvement of user representatives from companies of different sizes and industries. New requirements should be tested on end-to-end invoicing processes before they become mandatory.

 

3. Machine Readability and Consistent Mapping of Mandatory Invoice Details

Re marginal nos. 8–9 and 22–23

Users need standard-compliant, semantically unambiguous invoice data for automated processing as well as for automated invoice verification and posting. Deviating field assignments and business rule violations can impair this use, even if the mandatory VAT details are recognizable to humans. The tax classification under marginal nos. 22–23 should therefore be supplemented by clear application guidance.

Recommendations from eurofactura e.V.

We request that the mapping of the mandatory VAT details on the basis of EN 16931 and the consequences of non-compliance be clearly specified in the application guidance. This should be based on a uniform, standard-compliant, and machine-readable representation that supports automated invoice verification and posting.

For additionally specified field mappings, we request a non-objection period ending on December 31, 2027, provided that the e-invoice complies with the requirements of the BMF letters of October 15, 2024, and October 15, 2025.

 

4. Invoice Corrections

Re marginal nos. 20–21 and Section 14.11 para. 2 sentence 7 UStAE (new version)

Marginal nos. 20–21 provisionally permit practical corrections in the form of an e-invoice with a suitable invoice type, provided that the relevant details are clearly evident from an overall assessment. The treatment of collective corrections should be expressly clarified.

Recommendations from eurofactura e.V.

We request the following addition: “A correction in the form of an e-invoice may refer to several invoices, provided that the corrected details can be specifically and unambiguously allocated to each original invoice.”

We request the following clarification: “A subsequent specification of the invoice types to be used does not in itself give rise to an obligation to repeat a correction previously permissible under marginal no. 21.”

 

5. Description of Goods and Services and Supporting Documents

Re marginal nos. 10–14 and Section 14.5 para. 15 and Section 15.11 para. 3 UStAE (new version)

The required invoice details must be contained in the structured part. For supplementary contracts or proof of work performed, it should be clarified when separate retention is sufficient. Section 15.11 para. 3 sentence 6 UStAE limits the proof based on other business records provided for there to “other invoices.”

Recommendations from eurofactura e.V.

We request the following clarification: “If the mandatory VAT details, including the description of goods or services required for the control function, are fully contained in the structured part, further documents do not need to be embedded. Where they are required for evidentiary purposes, separate retention is sufficient, provided that they can be clearly allocated to the invoice and presented promptly. The specific requirements for embedded attachments under marginal nos. 4, 14, and 19 remain unaffected.”

We request that the non-objection rule under marginal no. 14 be continued until a new rule is expressly announced, and that a reasonable transition period be provided for its application.

 

6. Transitional Arrangement for Gross Price Invoices

Re marginal nos. 18–19

According to the letter, no gross invoice format is yet available for XRechnung and ZUGFeRD. Aligning the non-objection period with the one for final invoices would provide planning certainty.

Recommendations from eurofactura e.V.

We request the following extension: “The non-objection rule under marginal no. 19 applies, subject to the conditions set out therein, to e-invoices issued on or before June 30, 2030.”

 

7. Reasonable Deadline for Additional Requirements

Re the application provision (p. 10 of the letter)

The non-objection rule for additional requirements ends on December 31, 2026. From publication, this leaves only about two and a half months for adjustments and for testing invoice exchange.

Recommendations from eurofactura e.V.

We propose the following wording: “No objection will be raised – including for the purposes of input VAT deduction – if an e-invoice issued on or before December 31, 2027, complies with the requirements of the BMF letters of October 15, 2024, and October 15, 2025, but not with the additional requirements of this letter.” The statutory obligations to issue invoices and the transitional provisions remain unaffected.

 

eurofactura e.V. will gladly contribute use cases and technical expertise to the further dialogue.

 

Bielefeld, October 16, 2026

On behalf of eurofactura e.V. – The Board