Germany: BMF clarifies mandatory invoice elements must sit in the structured data, not an attachment
The Federal Ministry of Finance clarified that every mandatory invoice element must appear in the structured part of an e-invoice, not merely in an attached document or a PDF rendering. The clarification matters because a common shortcut in German implementations has been to satisfy EN 16931 structurally while leaving commercially negotiated detail in an attachment, on the assumption that the human-readable copy carries legal weight. It does not. With the issuing obligation arriving 1 January 2027 for businesses above EUR 800,000 turnover and all remaining businesses on 1 January 2028, mappings that lean on attachments need revisiting now rather than during the cutover.