Germany issues final BMF guidance letter on B2B e‑invoicing

1. From draft to final BMF guidance

Earlier in 2024, the German Ministry of Finance (BMF) published a draft guidance letter explaining how the new e‑invoicing rules would apply in practice, with the goal of raising awareness and helping taxpayers prepare. On 15 October 2024, BMF released the final version of this letter, largely maintaining the draft content but adding rewordings, rearranged sections and several important clarifications.​

The final letter provides a key interpretative framework for the Growth Opportunities Act’s e‑invoicing provisions and will be a primary reference point for businesses implementing the 2025–2028 roadmap.​

2. Main clarifications introduced in the final letter

The final BMF letter introduces or sharpens several points that matter directly for compliance:

• Storage of hybrid invoices:
  For hybrid invoices (for example, PDF with embedded structured data), the BMF now clearly states that the image component must be stored in its original form if it contains tax‑relevant information such as booking notes.​
• Receipt capabilities and email requirements:
  The draft letter had said that providing an email address was sufficient to meet the requirement to be able to receive e‑invoices from 1 January 2025.​
  The final version clarifies that businesses do not need a separate, dedicated electronic mailbox just for e‑invoices; an existing address or agreed channel can be used, as long as it fulfils the reception capability requirement.​
• Examples of accepted European formats:
  The letter now uses Peppol BIS as an example of another acceptable European electronic invoice format, replacing the earlier reference to Italy’s FatturaPA. This aligns the guidance more closely with the solutions commonly used in cross‑border B2B and B2G exchanges in Europe.​

These clarifications sit alongside the broader guidance in the letter on invoice formats, issuance and receipt rules, storage obligations, input VAT deduction and transitional provisions, giving German businesses a clearer operational roadmap for the e‑invoicing mandate