If you have supplied goods to a company in another EU country, or worked for one, without charging German VAT, you report these sales to the Bundeszentralamt für Steuern (BZSt, German Federal Central Tax Office). This is the Zusammenfassende Meldung, ZM for short, a report often explained in English as the EC Sales List or recapitulative statement. The deadline is the 25th day after the end of the reporting period; for most small businesses, that period is a quarter. For July to September 2026, the deadline therefore ends at the end of October. The report is filed electronically, most easily via ELSTER (the German tax authorities' online portal). Small business owners (Kleinunternehmer, businesses using the German small business VAT exemption) do not file a ZM, and for a quarter without such sales there is no report either.
Contents
- Do I have to file a ZM at all?
- Deadline: monthly or quarterly?
- What goes into the report
- Which month counts: invoice or service?
- How to file the ZM via ELSTER
- Does the ZM match the advance VAT return?
- ZM forgotten or late: the consequences
- Correcting an incorrect ZM
- Frequently asked questions
Do I have to file a ZM at all?
You file a ZM if, during the reporting period, you supplied goods without German VAT to a business customer in another EU country that has a VAT identification number (Umsatzsteuer-Identifikationsnummer, USt-IdNr.), or invoiced a service under the reverse charge procedure. Reverse charge means: the customer pays the VAT in their own country themselves, and your invoice shows none. The legal basis is § 18a UStG (the German VAT Act).
| Your situation | File a ZM? |
|---|---|
| Goods to a company in France, without German VAT, with its USt-IdNr. | yes |
| Web design, consulting or programming for a company in Austria, invoice with a reverse charge note | yes |
| Sales to private customers in the EU | no |
| Customer in Switzerland, the United Kingdom or another country outside the EU | no |
| Purchase from a supplier in another EU country | no, according to the BZSt purchases are not reported |
| You are a small business owner under § 19 UStG | no, not even if you have a USt-IdNr. |
| In the quarter, none of the sales from the first two rows occurred | no, a nil return is not provided for |
Two rare cases also belong in the ZM: supplies in an intra-Community triangular transaction (innergemeinschaftliches Dreiecksgeschäft) and movements of goods into a consignment stock (Konsignationslager) in another EU country. If these affect you, it is best to clarify the details with your tax adviser.
It does not work without your own USt-IdNr., because the number appears in every report. How to apply for one and check your customer's number is explained in the article Applying for and checking a USt-IdNr.. What belongs on the invoice itself is explained in Invoicing customers in other EU countries. In the office1.cloud invoicing software, you store the USt-IdNr. of your business customers with the respective customer and check it there directly.
Deadline: monthly or quarterly?
If you only invoice services to EU companies, you report quarterly, in each case by the 25th after the end of the quarter. The same applies to supplies of goods as long as they do not exceed 50,000 euros per quarter. Above that, you report monthly.
| Quarter | ZM due by |
|---|---|
| January to March | 25 April |
| April to June | 25 July |
| July to September | 25 October |
| October to December | 25 January |
If the 25th falls on a weekend or a public holiday, the safest option is to transmit the report on the working day before.
When do you report monthly? Only supplies of goods to EU companies are decisive; services do not count towards the threshold. If their total exceeds 50,000 euros in the current quarter or in one of the four preceding quarters, the reporting period is the calendar month. The switch happens automatically; the BZSt does not write to you about it. The BZSt gives an example: a retailer who has so far reported quarterly reaches 57,000 euros in May. They file a ZM for April and May by 25 June and report every month after that.
Services for monthly filers: If you report monthly because of supplies of goods, you enter the services in the ZM for the last month of the quarter. You may also include them every month.
Voluntarily monthly: You may also report monthly below the threshold. To do so, tick the box provided for this in the first monthly report. According to the Umsatzsteuer-Anwendungserlass (the German VAT application decree, the tax authorities' administrative guidance), this choice is binding for at least twelve months.
Annually only in exceptional cases: An annual report by 25 January is only permitted if the tax office has exempted you from filing advance VAT returns (Umsatzsteuervoranmeldungen), your total turnover in the previous year was no more than 200,000 euros and your EU sales no more than 15,000 euros. Neither threshold may be expected to be exceeded in the current year either.
No permanent deadline extension. The one-month deadline extension (Dauerfristverlängerung) that many businesses have for the advance VAT return does not apply to the ZM. If you cannot meet the deadline in an individual case, you can, according to the BZSt, apply to the BZSt for an extension before the deadline expires, stating your reasons.
What goes into the report
The ZM contains one row per customer: their USt-IdNr. with country code, the total of the net amounts in the reporting period and the type of sale. You do not have to list invoices individually.
| Column | What goes in |
|---|---|
| Customer's USt-IdNr. | with country code, for example FR or AT at the start |
| Total of the taxable amounts (Summe der Bemessungsgrundlagen) | net amounts of all sales to this customer in the reporting period |
| Type of sale | supply of goods, other service (sonstige Leistung, i.e. a service) or triangular transaction |
If a customer received both goods and a service in the same period, the report contains two rows for them, one per type. Convert amounts in foreign currency into euros.
Example: A web designer from Cologne sends an agency in Vienna three invoices of 1,200 euros each in the third quarter, all without VAT and with a reverse charge note. In her ZM for July to September, she enters one row: the agency's Austrian USt-IdNr., 3,600 euros and, as the type, other service. She must transmit it by 25 October.
Which month counts: invoice or service?
For services, what counts is the period in which you performed the service. When you write the invoice makes no difference here. For supplies of goods, by contrast, the month of the invoice counts, but at the latest the month after the supply.
An example for goods: you deliver to Belgium on 28 September and write the invoice on 2 October. The supply then belongs in the reporting period that includes October. If you only write the invoice in November or later, it still stays with October, because that is the month after the supply (§ 18a Abs. 8 UStG).
Whether you pay VAT on the basis of agreed consideration (Soll, accrual basis) or on receipt of payment (Ist, cash basis) makes no difference to the ZM. The Umsatzsteuer-Anwendungserlass explicitly clarifies this in section 18a.3.
How to file the ZM via ELSTER
The ZM goes electronically to the BZSt, not to your tax office (Finanzamt). Two routes are available: the Zusammenfassende Meldung form in ELSTER or the BZSt online portal (BZSt-Online-Portal). If you already have an ELSTER account for the advance VAT return, ELSTER is the shorter route.
- Log in with your existing ELSTER account. According to the BZSt, you do not need a second account, nor a separate registration for the ZM.
- Open the form for the Zusammenfassende Meldung.
- Enter your own USt-IdNr. and the reporting period.
- Enter one row per customer and type of sale. If you have many customers, you can also import the rows from a CSV file; the form accepts up to 1,500 rows.
- Submit the report and file the proof of transmission with your records.
In Easy Invoice, a dedicated ZM report compiles the sales per customer and period and outputs them as a PDF. From there, you transfer the figures into the form.
The BZSt online portal additionally requires registration for the ZM procedure (Fachverfahren ZM). According to the BZSt, the portal is only mandatory for so-called bulk filers (Massenmelder) with a very large number of report rows. A ZM on paper is only possible if the tax office permits it on application, for example because electronic filing cannot reasonably be expected of you. If your tax adviser handles the report, according to the BZSt they transmit the ZM for you with their own access.
Does the ZM match the advance VAT return?
Yes. The same sales appear in your advance VAT return, and the BZSt compares the two sets of figures. If they differ, you receive a letter asking you to correct them.
| Sale | Advance VAT return 2026 | ZM |
|---|---|---|
| Supply of goods to an EU company with a USt-IdNr. | Zeile (line) 19, Kennzahl (box code) 41 | type: supply of goods |
| Service to an EU company, the customer owes the tax | Zeile (line) 35, Kennzahl (box code) 21 | type: other service |
The assignment comes from the official notes on the 2026 advance VAT return. If you file the advance VAT return monthly and the ZM quarterly, a quick comparison helps: the total of the three months against the quarterly report.
ZM forgotten or late: the consequences
For supplies of goods, a missing or incorrect ZM can be expensive: the tax exemption then no longer applies, and you owe German VAT on the supply. This is set out in the law (§ 4 Nr. 1 Buchst. b UStG). The good news is in the Umsatzsteuer-Anwendungserlass, section 4.1.2: if you submit the ZM correctly and completely after the fact, the exemption is granted retroactively, as long as the tax assessment can still be amended.
In addition, the BZSt has these means:
- Reminder and enforcement penalty (Zwangsgeld). If a ZM is missing, the BZSt requests it. If it still does not arrive despite a warning, the BZSt can impose an enforcement penalty. Paying it does not settle the obligation; the ZM is still required.
- Fine (Bußgeld). Anyone who intentionally or recklessly fails to file a ZM, or files it incorrectly, incompletely or late, commits an administrative offence. A fine of up to 5,000 euros is possible (§ 26a UStG).
How the BZSt knows about a missing ZM: if you declare sales in the advance VAT return that belong in the ZM, according to the BZSt this automatically results in an obligation to file the ZM.
Correcting an incorrect ZM
If you notice that a ZM you have filed is incorrect or incomplete, the law requires you to correct it within one month (§ 18a Abs. 10 UStG). The correction is always made to the report for the period that contains the error. Simply offsetting the error in the next ZM is not enough: according to the Umsatzsteuer-Anwendungserlass, for supplies of goods this does not save the tax exemption.
The correction is made electronically via the same form, where you confirm the field for the correction. The BZSt does not accept corrections in writing or by phone. The corrected report contains only the changed rows. The BZSt describes the most common cases as follows:
| Error | How to correct it |
|---|---|
| Sale forgotten | corrected ZM for this period, containing only the missing sale |
| Wrong amount | corrected row with the correct amount |
| Wrong customer USt-IdNr. | row with the wrong number and the amount 0, plus a row with the correct number and the amount |
| Wrong period | correct the row to 0 in the wrong period, report it in the correct period |
| Wrong type of sale | old row with 0, new row with the correct type |
A discount, credit note or cancellation is not a correction. If the amount changes afterwards, for example due to a price reduction or because the customer does not pay, report the change in the period in which it occurs. There you offset it against the new sales to the same customer. The total may also be negative. How to show the discount correctly to the customer is explained in the article Creating a credit note.
Frequently asked questions
Do I have to file the ZM even if I have not sold anything?
No. For a reporting period without supplies or services to EU companies, no ZM has to be transmitted. You only enter a 0 if a credit note exactly cancels out the total for a customer.
Do I have to file a ZM as a small business owner?
No. Small business owners under § 19 UStG are exempt; this is set out in § 18a Abs. 4 UStG. According to the BZSt, this also applies if you have a USt-IdNr. If you nevertheless receive a request, the BZSt advises checking your annual VAT return (Umsatzsteuererklärung): if it contains sales for which a ZM would be required, the return is corrected; otherwise, the tax office will help you further.
Does the Dauerfristverlängerung apply to the ZM?
No. The one-month extension only applies to the advance VAT return. The ZM remains due on the 25th day after the end of the reporting period.
Do I also have to file an annual report?
No. According to the BZSt, anyone who reports quarterly or monthly does not file an additional annual return for the ZM.
Where does the ZM go: tax office or BZSt?
To the Bundeszentralamt für Steuern. The advance VAT return goes to your tax office, the ZM goes to the BZSt via ELSTER or the BZSt online portal.
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Sources
- § 18a UStG, Zusammenfassende Meldung (recapitulative statement), in German
- § 4 UStG, tax exemptions (Steuerbefreiungen), no. 1 letter b, in German
- § 26a UStG, provisions on fines (Bußgeldvorschriften), in German
- BZSt: Zusammenfassende Meldung, in German
- BZSt: Obligation to file (Abgabepflicht), in German
- BZSt: Deadlines (Fristen), in German
- BZSt: Electronic filing and data transmission (Elektronische Abgabe und Datenübermittlung), in German
- BZSt: Correcting a ZM (Berichtigung einer ZM), in German
- BZSt: Questions and answers on the ZM (Fragen und Antworten zur ZM), in German
- Umsatzsteuer-Anwendungserlass (VAT application decree), as of 2 June 2026, sections 4.1.2 and 18a.1 to 18a.5 (BMF, Federal Ministry of Finance), in German
- BMF: Form template for the 2026 advance VAT return with instructions (Vordruckmuster Umsatzsteuervoranmeldung 2026 mit Anleitung), in German
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