Germany Responds to Business Feedback – revised e-invoicing draft issued by BMF on June 25, 2025

On June 25, 2025, Germany’s Federal Ministry of Finance (BMF) published a revised draft of its administrative guidance on mandatory e-invoicing for domestic B2B transactions. The new version introduces several important clarifications and adjustments compared to the previous version dated October 15, 2024 – many of which respond directly to concerns raised by businesses and service providers.

What’s new?

1. Technical errors no longer disqualify invoices completely 

Structurally or content-wise flawed e-invoices are not considered valid under the new rules – but they remain effective for VAT purposes. Corrections are possible retroactively, which helps preserve the input VAT deduction.

2. Exemption for small businesses 

Taxable persons with turnover below €22,000 (per § 19 German VAT Act) are no longer required to issue e-invoices.

3. No consent required for voluntary e-invoicing 

Where no legal obligation exists, a compliant e-invoice can still be issued – and must be accepted by the recipient without prior consent.

4. Clarification on barter transactions involving used parts 

Where the residual value of a returned part is treated as consideration, the related VAT must be disclosed using a dual-line item approach in the e-invoice (one positive, one negative).

5. Concrete wording for the VAT Application Decree (UStAE) 

For the first time, the draft includes proposed legal language for the upcoming changes to the UStAE – offering greater clarity and predictability for implementation.

Our view 

This revised draft improves legal certainty and usability for businesses. By addressing core concerns of the market, the BMF takes a major step toward ensuring that the German e-invoicing obligation can be implemented in a pragmatic and business-friendly way.

The draft guidance is expected to be finalized in Q3 2025.