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A year after publishing its first circular on e-invoices, the Federal Ministry of Finance (BMF) has published a second circular to further define the rules on electronic invoicing. The Circular, dated 15 October 2025, updates the Circular of 15 October 2024 and amends the VAT Application Decree (Umsatzsteueranwendungserlass – UStAE). In this article, we explain the main changes and clarifications in the second Federal Ministry of Finance circular on e-invoicing. Businesses should familiarise themselves with the new requirements to check and validate e-invoices in advance to efficiently push forward the digitalisation of their invoicing processes.

From 1 January 2025, German businesses will have to be able to receive and process e-invoices. Which challenges does the retail sector have to be aware of at the end of the year, and how can it make use of the opportunities it brings?