BMF letter of 15 October 2025

Input VAT deduction & input VAT protection for e-invoices

A defective incoming invoice can put your input VAT deduction at risk. The BMF (German Federal Ministry of Finance) grants input VAT protection here (Vertrauensschutz, protection of legitimate expectations) if you have checked the invoice with a suitable validation tool and kept the check report. That is exactly what our check report provides automatically.

What the BMF letter requires

The BMF letter of 15 October 2025 is a guidance letter from the German Federal Ministry of Finance. It amends the VAT Application Decree (Umsatzsteuer-Anwendungserlass, the administrative guidelines of the German tax authorities) and distinguishes three types of error in e-invoices: format errors (margin no. 6a, the file is not a syntactically valid e-invoice), business rule errors (margin no. 6b, e.g. a missing mandatory field or an arithmetically incorrect tax total) and content errors (e.g. a wrong tax rate). Whether a format or business rule error exists can be checked with a suitable validation application.

Wording (margin no. 35a, our unofficial translation of the German original): “A business owner who exercises the due care of a prudent merchant may rely on the technical result of a validation (with regard to format and business rules) by a suitable validation application. As evidence, it is advisable to retain the validation report.”

Source: BMF letter of 15 October 2025, margin no. 35a (bundesfinanzministerium.de, in German) ↗

What the protection covers, and what it does not

Covered

Format & business rules

If a suitable validation application has found no format or business rule error, you may rely on that result provided you exercise due care. That is the actual protection.

Not covered

Content errors

A wrong tax rate or an incorrect description of the goods or services is not detected by the format check. The duty to check the invoice for completeness and accuracy remains with the invoice recipient; validation supports this but does not replace it.

Our check report: the evidence recommended by the BMF

Every incoming invoice you check with us, whether via the free web form or automatically via your connected mailbox, is checked against the official KoSIT validator (EN 16931) and additionally examined for manipulated bank details. For every check, a dated check report (PDF) is available to download and file with your accounting records: exactly the evidence the BMF letter recommends.

1. Check

Upload the incoming invoice or receive it automatically via your mailbox.

2. Record

The KoSIT result and the IBAN check are recorded with the date.

3. Retain

Download the check report (PDF) and file it with your records, free in every account.

FAQ: input VAT deduction & input VAT protection

What is a “suitable validation tool” within the meaning of the BMF letter?

The BMF letter of 15 October 2025 does not name a fixed list, but a suitable validation application that checks an e-invoice for format errors and business rule errors under EN 16931, for example against the official KoSIT validator. Our platform automatically checks every uploaded incoming invoice with exactly this validator and records the result.

Does the protection also cover content errors such as a wrong tax rate?

No. Under margin no. 35a of the BMF letter, the protection expressly applies only to the technical result of the validation (format and business rules). Content errors, such as a wrong tax rate or an incorrect description of the goods or services, are not detected by format validation and remain the invoice recipient's responsibility to check.

Do I really have to keep the validation report?

The BMF expressly recommends it as evidence of due care: “As evidence, it is advisable to retain the validation report” (margin no. 35a, our unofficial translation). That is why a downloadable check report (PDF) is available for every checked incoming invoice, which you can file with your accounting records.

What is the difference between a format error and a business rule error?

A format error exists if the invoice file does not conform to the permitted syntax; the file is then not considered an e-invoice (margin no. 6a). A business rule error exists if the file is technically correct but violates a validation rule, for example a missing mandatory field or an arithmetically incorrect tax total (margin no. 6b). The KoSIT validator detects both.

How do I get the check report for an incoming invoice?

Every incoming invoice checked via “Check e-invoice” or the connected mailbox appears in your check history. There, a check report (PDF) is available to download for each result, with the KoSIT result, IBAN check and date. Included free in every account, at no extra cost.

Note: this guide summarises the BMF letter of 15 October 2025 but does not replace tax advice. The final assessment in each individual case rests with the German tax authorities.

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