Germany updates official FAQ on mandatory e‑invoicing
The latest BMF FAQ clarifies who must issue e‑invoices, how UStG and ERechV interact, applicable thresholds, and ELSTER viewer support for XRechnung and ZUGFeRD.
Table of Contents
1. New FAQ version and purpose
On 5 November 2025, the Federal Ministry of Finance (Bundesministerium der Finanzen, BMF) published an updated FAQ on the introduction of mandatory e‑invoicing from 1 January 2025. The “October 2025” version keeps the existing definitions, transmission channels and timelines, but adds important clarifications and updated legal references.
The FAQ is available on the BMF site: BMF e‑invoice FAQ.
2. Scope clarifications and legal interaction
Key new points include:
- Foreign businesses without a fixed establishment in Germany:
Companies with German VAT registration but no fixed establishment can indicate this status on their invoices to justify exemption from mandatory e‑invoice issuance. Recipients may rely on this indication when exercising normal commercial care. - Relationship between UStG and ERechV:
A new section explains that the German VAT Act (Umsatzsteuergesetz, UStG) and the Federal E‑Invoicing Ordinance (E‑Rechnungsverordnung des Bundes, ERechV) do not have a hierarchical relationship but must be applied in parallel within their respective scopes.
One example used in the FAQ highlights differing thresholds and channels:
- Under the VAT Act, an e‑invoice is required for transactions above 250 EUR.
- Under ERechV, the obligation applies to federal B2G invoices from 1,000 EUR.
- For B2B transactions, the VAT Act allows various transmission methods, while for federal B2G invoices, OZG‑RE must be used as the receiving platform.
3. ELSTER viewer support and updated references
The updated FAQ notes that the ELSTER viewer now supports both XRechnung and ZUGFeRD formats, making it easier for taxpayers and auditors to display and review structured e‑invoices. The viewer is accessible here: ELSTER e‑invoice viewer.
The FAQ also consolidates and refreshes legal references, including:
- The BMF e‑invoicing letters dated 15 October 2024 and 15 October 2025.
- The 14 July 2025 GoBD amendment on retention and data access requirements.
These updates help businesses navigate overlapping rules and ensure their e‑invoicing processes remain aligned with the latest German VAT and compliance guidance.
