Germany clarifies e-invoice data requirements and transitional relief

The letter amends the Umsatzsteuer-Anwendungserlass, notably sections 14.1, 14.5, 14.11 and 15.11. The underlying framework is section 14 of the Umsatzsteuergesetz (UStG): an e-invoice uses a structured electronic format permitting electronic processing. Domestic business-to-business supplies generally require that format where both parties meet the statutory domestic-establishment test, subject to exemptions and transition rules.^[1][2]

Structured data and supporting documents

The required service description must identify the supply sufficiently to determine its VAT treatment; every supporting detail need not appear in the structured fields. Supplementary information may be embedded as an attachment. For construction invoices, the guidance accepts trade-level totals in the structured part with a clearly referenced, embedded, readable detailed bill of quantities.^[1][2]

For gross-price invoices issued by 31 December 2027, temporary relief permits structured totals by VAT rate or exemption, with individual descriptions in a referenced embedded attachment. For electronic final invoices using the specified attachment approach, relief for deducting previously received instalments is extended to 30 June 2030. These concessions do not generally extend mandatory e-invoicing.^[1]

Corrections and VAT treatment

Section 31(5) of the Umsatzsteuer-Durchführungsverordnung (UStDV) permits correction of missing or inaccurate particulars through a document specifically identifying the invoice, subject to section 14’s form and content rules. The new letter says that, where e-invoicing is mandatory, the correction must also be an e-invoice; currently any workable correction approach using a suitable invoice type is accepted if the final particulars are clear.^[1][4]

Application and group systems

The letter applies to supplies after 31 December 2024, respecting existing transitions. Section 27(38) UStG permits ordinary invoices through 2026 and specified smaller-supplier or EDI cases through 2027. Separately, e-invoices issued by 31 December 2026 following the 2024 and 2025 letters will not be challenged solely for failing additional requirements in this letter, including for input VAT. Group finance teams should distinguish these timelines when updating German invoice templates and validation controls.^[1][3]