Errors in the validation report: is the e-invoice still valid?

A validator reports errors in an e-invoice. What does that mean for tax purposes? The German Federal Ministry of Finance distinguishes three kinds of error in its letter of 15 October 2025 ^[1]. This article reports what the letter says and shows how to read the messages in a validation report. It is not tax advice.

Format errors

A file that does not meet the requirements of the structured e-invoice format because of format errors is, according to the ministry, a "sonstige Rechnung" in another electronic format ^[1].

Business-rule errors

According to the ministry, business-rule errors arise when the details in an invoice are incomplete or contradict each other. The letter gives two examples: a missing entry in the mandatory field BT-10 (Buyer reference) of an XRechnung, and a tax amount that does not arithmetically match the stated rate ^[1].

Content errors

Where the mandatory VAT details of §§ 14(4) and 14a UStG are breached, the ministry says the invoice is not a proper invoice. Such content errors can be detected during validation as a breach of the corresponding business rules ^[1].

Business-rule errors concerning other content are, according to the same letter, irrelevant for VAT; its example is the missing BT-10 field ^[1]. Conversely, content errors can exist even when validation found no error, for example a wrong tax rate ^[1].

What a validation report can do

• According to the ministry, validation is not a direct precondition for the invoice being recognised for tax purposes ^[2].
• A business that exercises the care of a prudent merchant may, according to the letter, rely on the technical result of a validation by a suitable validation application. As evidence, the ministry suggests keeping the validation report ^[1].
• According to the ministry, validation does not replace the recipient's duty to check the invoice for completeness and correctness ^[1].
• The ministry does not recommend any particular validation application ^[2].

How to read the messages

• Ids such as BR-DE-15, BR-CO-15 or BR-S-08 name business rules from the norm EN 16931 or from the German XRechnung rules. For many of them we have a page explaining what the rule checks and how to fix the error.
• Messages with ids such as cvc-complex-type come from the schema check. It runs before the business rules and concerns the structure of the file, for example a missing element.
• A warning, such as BR-DE-19, does not stop the validator accepting the file. An error does.

How a particular error is to be classified for tax purposes is not something the report tells you. If in doubt, settle it with your tax adviser.

When an e-invoice is corrected

According to the ministry, the correction of an e-invoice must likewise take the form prescribed for it, using the corresponding invoice type ^[1].