Interim and final invoices and measurement in e-invoicing

Interim invoices that you issue before your mandatory date do not yet have to be e-invoices (E-Rechnung). For the final account, a relief applies until 30 June 2030: the interim payments received may appear in the data set as a total, with the details following in the free-text field or in an embedded attachment. At present the bill of quantities (BoQ, Leistungsverzeichnis) may be attached as a readable annex if the data set holds only the trades with their totals. On site measurement (Aufmaß) the letters say nothing explicit; the obvious course is to carry it along as an embedded annex, like a time sheet.

1. Interim, before date Paper or, with consent, PDF (BMF 2026, para. 2)
2. Interim, from date Must be an e-invoice
3. Bill of quantities Trades with totals in the data set, details as annex
4. Final account Interim payments in BT-113, details in BT-22 or annex

Text version of the graphic

• 1. Interim, before date: Paper or, with consent, PDF (BMF 2026, para. 2)
• 2. Interim, from date: Must be an e-invoice
• 3. Bill of quantities: Trades with totals in the data set, details as annex
• 4. Final account: Interim payments in BT-113, details in BT-22 or annex

The rules on the final account and the bill of quantities come from letters of the Federal Ministry of Finance (Bundesfinanzministerium, BMF) and are non-objection rules: the tax authorities do not object to the approach as long as the technology of the e-invoice cannot yet represent the details in full. The rule on interim invoices, by contrast, clarifies that interim invoices before the mandatory date need not be e-invoices. The BMF intends to review all these rules in due course in view of the requirements of the planned reporting system and to adjust them if necessary (BMF 2026, para. 1). For the final account the BMF names an end date; for the bill of quantities it says only “currently”. Below, “BMF 2024” and “BMF 2026” mean the BMF letters of 15 October 2024 and 15 October 2026, and “para.” refers to the numbered paragraphs (Randnummern, Rn.) of those letters. When your mandatory date falls is covered in the article E-invoice deadlines in construction: which date applies to you.

Interim invoices before and after the mandatory date

Down-payment, advance and interim invoices that you issue before the date that binds you, taking the transitional rules into account, do not have to be sent as e-invoices. That also applies if the work and the payment follow only afterwards (BMF 2026, para. 2). An electronic format other than paper, such as a PDF, still requires the recipient’s consent (section 27(38) of the German VAT Act, Umsatzsteuergesetz, UStG).

An example with invented figures: A construction company with prior-year turnover of 900,000 euros must issue e-invoices from 1 January 2027. Its interim invoice of 15 December 2026 may still come on paper or, with the client’s consent, as a PDF, even if the building work runs until autumn 2027. The interim invoice of 15 February 2027 is an e-invoice.

That creates a pitfall. The final account must deduct the interim invoices issued earlier, where invoices with separately stated tax were issued for them (section 14(5) UStG; BMF 2024, para. 47). Some of these interim invoices then exist as PDFs, others as data sets.

The final account

The BMF letter of 2024 concedes that the requirements for a final account cannot yet be mapped in the structured part. It considers issuing a balance invoice (Restrechnung) instead the obvious course (paras 47 and 48). Which form suits your project depends on how many interim invoices there are and in which format they were issued. The 2026 letter names two routes that will not be objected to until 30 June 2030:

• Total in the data set: the partial payments already received are deducted as a total in field BT-113 (“Paid amount”). The required details are in the free-text field BT-22 (“Invoice note”) (para. 3).
• Embedded attachment: the deduction is made in an unstructured attachment that meets the requirements of section 14.8(8) no. 2 of the VAT application decree (Umsatzsteuer-Anwendungserlass, UStAE). The data set must expressly refer to this annex (para. 4).

Sending a special summary of the interim payments separately is not possible for an e-invoice (BMF 2024, para. 48). You must embed the attachment in the file.

Bill of quantities

Invoices for construction work are often issued on the basis of the bill of quantities, which is normally a sufficient description of the service. The core data model of the standard cannot currently represent the BoQ in the structured part, however (BMF 2026, para. 13).

It is therefore not objected to if the data set contains, as the description of the service, only the trades with their totals. A human-readable, embedded annex must then contain the breakdown according to the bill of quantities, and the data set must refer to it clearly. In addition, the BoQ may be sent along as a structured file, for example in the GAEB standard (the German exchange format for bills of quantities). Under civil law the contracting parties may also agree another suitable method, such as an extension that carries the BoQ in the data set itself (para. 14). In its questions and answers the Federal Chamber of Tax Advisers gives 30 June 2030 as the date for this rule. The BMF letter and the BMF questions and answers (question 7b) say only “currently” for the bill of quantities.

Site measurement and time sheets

The term for site measurement (Aufmaß) appears in the BMF letters only as an example of changes to the service (BMF 2025, para. 51b). They do not regulate how a site measurement is to be attached to the invoice. They set out a general principle: the data set must describe the service so that type, scope and tax rate can be checked. Further details that are not needed for that, such as the breakdown of time sheets, may follow as an embedded attachment (BMF 2026, para. 12). It seems reasonable that a site measurement, like a time sheet, can be carried along as an embedded annex. That is, however, a deduction from the general principle and not an explicit statement. Whether your site measurement belongs among the details that must already be in the data set depends on the individual case, and your tax adviser (Steuerberater) clarifies that.

A second question is contractual: what your construction contract requires for an auditable invoice is not regulated by VAT law. That stays between you and your client and, in a dispute, together with your lawyer.

Technically, ZUGFeRD (a German e-invoice format) embeds accompanying documents Base64-encoded in the XML. According to the FeRD FAQ, this is possible only in the EN 16931 and EXTENDED profiles. What this looks like in the data set is shown in the article XRechnung and ZUGFeRD: what the data set holds, how to read it.

Early-payment discounts, bonuses and correction

In construction, early-payment discounts (Skonto) and bonuses are common. The BMF requires that every reduction in the consideration agreed in advance be stated, unless it is already included in the consideration. If the amount is not yet fixed when the invoice is issued, the invoice must clearly refer to the agreement. A general reference is not objected to if the written agreement can be produced within a short time (BMF 2026, paras 15 and 16).

The BMF letter of 15 October 2025 distinguishes two cases. If only the tax base is reduced, for example by an early-payment discount or by a reduction after a notice of defects that has no consequences for the service invoiced, no correction is needed (para. 51a). If, on the other hand, the scope or content of the service changes, for example through relevant changes in the site measurement, the description of the service must in principle be corrected. With prior agreement, this can also be done as a credit note from the recipient of the service (para. 51b).

For corrections, the rule is: if the e-invoice obligation applies, the correction must also be an e-invoice, with the invoice type for a correction. Which type to choose for replacing or cumulative corrections and for commercial credit notes has not yet been fixed technically. For tax purposes, the invoice and the corrections taken together must show clearly what was actually invoiced (BMF 2026, paras 20 and 21). That matters for variations (Nachträge) and quantity changes in construction.

Section 13b UStG in brief

The e-invoice obligation also applies to supplies where the recipient of the service owes the tax (section 13b UStG, the reverse-charge rule), if both parties are established in Germany (BMF 2024, para. 17). How such invoices are to be treated for tax purposes is for your tax adviser to clarify.

What you can do now

1. Collect the building projects where interim invoices will still be issued before your mandatory date and the final account follows afterwards.
2. Ask the maker of your construction software whether it attaches the BoQ as an embedded attachment and shows the interim payments in BT-113.
3. Check with a client in which form it expects site measurement and time sheets.
4. Clarify with your tax adviser whether, for ongoing building projects, you should choose balance invoices or final accounts with an attachment.

General information, not legal or tax advice. Your tax adviser clarifies the individual case. As of 13 November 2026.