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German Bundesministerium der Financzen (BMF) Releases a Letter Clarifying Supplier Obligations

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Susie West
Oct 20, 2025
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Some might say: The German Mandate is Causing Confusion. The BMF Letter Should Help.

 With 10 months behind us, it’s been an interesting implementation so far.

 The story and timelines so far:

  •  January 1st 2025: The phased rollout began – all businesses must be capable of receiving e-invoices in a structured e-format compliant with EN16931.
  • Electronic invoices sent in compliant formats cannot be refused.*
  • Paper and PDF invoices allowed - no obligation to send electronic invoices
  • January 1st 2027: Large businesses (revenue of >€800K) must issue compliant e-invoices.
  • Paper/simple PDF invoices prohibited, unless the recipient has explicitly agreed to accept them
  • January 1st 2028: ALL businesses must issue compliant e-invoices

 Thumbs Up:

  • The gradual rollout gives companies a chance to prepare and look at wider finance and tax transformation across their organization
  • The deadline schedule is sympathetic to smaller organizations who likely need more time and support, as a group, to onboard
  • The mandate is supplier-led. This is a refreshing breakaway from traditional buyer-led e-invoicing programmes. Suppliers own the choice of which service provider they work with
  • Germany is aligning early with the ViDA directive, and international companies based out of Germany will benefit from future pan-European rules

 Thumbs Down:


  • Accuracy rates are low (one provider says 50% of e-invoices processed for Germany fail)
  • The model is not yet defined at a national level – there’s ambiguity around if Germany will opt for a centralized, decentralized, 4-corner or 5-corner model
  • ZugFerd and Factur X uses PDF as a container for its electronic invoice – this frustrates service providers by adding work
  • Take-up is low. As of September 2025, only 20 - 25% of companies were sending electronic invoices and 30% receiving**
  • Lack of standards is slowing things down
  • The PDF/XML hybrid format looks untenable for the future
  • The more relaxed timeline is causing confusion among taxpayers
  • No official timelines yet on e-reporting (DRR)
  • Technical issues need to be fixed

 Positive News:

Recently the German Ministry of Finance (BMF) released new guidance on the three-year rollout of B2B e-invoicing.

 The new BMF Letter addresses changes that will help reduce the 50% fail rate (please note the German government believes the fail rate to be lower). It explains:

  • Non-conforming files (invoices in the wrong format, with missing/non-extractable VAT fields), will lose their e-invoice status, and the supplier would need to remedy it
  • If data is missing and VAT rules are violated (i.e. incorrect amounts, missing tax rates, incorrect total amount), the invoice will become “improper.” But it might still keep its e-invoice status
  • Suppliers may want to work with validation tools to check that fields are complete and correct, BUT this is not a shift in responsibility. The responsibility still sits with the Supplier to ensure it’s sent a proper and compliant electronic invoice
  • When validation checks happen, keep the reports.

Why this matters:

  • This letter is putting an emphasis on Suppliers checking their invoices before they’re sent
  • The letter also clarifies that not all errors are equal – some errors mean the e-invoicing loses its status and other mean the e-invoice remains such, but becomes improper
  • These errors will have an impact on VAT deductions

 If you’re going live in Germany, join us for our upcoming webinar: https://tinyurl.com/2cb3epb5

*Unless the invoice value is less than €250 or the transaction is B2C

** Presentation by Richard Luthardt and Ivo Moszynski at the E-Invoicing Exchange Summit, September 2025, Vienna