How Belegomat interprets the BMF guidance on business-meal receipts

One note up front: this text reflects our understanding of the rules. It is general information, not tax advice. Whether a receipt is accepted in a given case is decided by your Finanzamt (tax office), and the assessment of your specific situation belongs with your Steuerberater (tax adviser).

The legal basis

The relevant provision is § 4 Abs. 5 Satz 1 Nr. 2 EStG, interpreted by the BMF letter on the tax recognition of business-meal expenses (originally dated 30 June 2021, continued by the letter of 19 November 2025).

For the proof, the law requires written details on five points:

• the place of the meal
• the day of the meal
• the participants
• the occasion (business reason)
• the amount of the expense

For a meal in a restaurant, the restaurant invoice must also be attached. The self-issued receipt (Eigenbeleg) itself then needs to carry the occasion and the participants; the remaining details follow from the attached invoice.

The Eigenbeleg, and its signature or approval

The BMF describes the receipt as an informal document that the taxpayer creates promptly. Under established case law, this Eigenbeleg is to be signed by the taxpayer.

For the digital world, the BMF has made this more concrete. We understand the guidance as follows:

• the Eigenbeleg may be created digitally
• authorisation may take the form of an electronic signature or an electronic approval of the entries
• a qualified electronic signature, a certificate or a signature card are not expressly required for this
• what matters is that the approval is documented and that the entries cannot later be changed without that change being documented

The BMF also names conditions under which the proof requirements are regarded as met: a promptly created electronic Eigenbeleg with the required details, the recording of the creation time in the document, a digital signature or approval by the taxpayer, the recording of the time of that approval, electronic storage together with the invoice, and compliance with the GoBD (the principles for proper electronic bookkeeping and retention).

We are not aware of any court ruling on whether a confirmation given through a messenger qualifies as an electronic approval in this sense. We read the guidance to mean that a documented, time-stamped consent comes close to the picture of electronic approval that the BMF describes. The final judgment remains with the tax office and your tax adviser.

How Belegomat is designed to respond

Belegomat turns your entries into a structured Eigenbeleg. The product is designed to reflect the points above:

• the five statutory details are captured in an orderly way: place, day, participants, occasion and amount
• participants are recorded by name, with a note on whether they are employees or external guests
• the photo of your invoice is attached to the Eigenbeleg as a further page, so that the receipt and the invoice are joined in a single document
• before the document is generated, you explicitly confirm the captured details. We understand this step as the electronic approval that the BMF describes
• the time of creation and of confirmation is recorded in the document
• the receipt also carries machine-readable details that make later matching and processing easier

Belegomat is deliberately a quiet, narrowly defined tool. Its job is to help you create a clean Eigenbeleg, and nothing beyond that.

What stays with you and your tax adviser

Several points that are decisive for recognition lie beyond what a receipt tool can do. We name them openly:

• Quality of the invoice. The restaurant's invoice must be machine-generated and electronically recorded, must itemise the food and drink individually and, depending on the amount, must contain further mandatory details. Belegomat attaches the photo you provide; the formal correctness of the invoice itself is not in our hands.
• Specificity of the occasion. The occasion should be concrete. General phrasing tends not to be sufficient. Belegomat points out entries that look too generic, but the wording is yours.
• Timeliness. The details must be created promptly. When you create the receipt is up to you.
• Retention. The receipt must then be stored so that it cannot later be changed without documentation (GoBD). Belegomat creates the document and hands it to you; the unalterable, GoBD-compliant storage happens on your side, for example in your document management system.
• Tax treatment. The limitation of the deduction to 70 percent, the treatment of input VAT, and the distinction between business and operational hospitality are questions of bookkeeping. They belong with your tax adviser.

A note on currency

The administrative view continues to evolve. The letter of 30 June 2021 applies to meals up to 31 December 2024; for later periods the letter of 19 November 2025 governs, which mainly adds rules on the E-Rechnung (electronic invoice). The interpretation described here may change with future letters or case law.

In short

Belegomat is designed to create a proper Eigenbeleg that captures the details named by the BMF in a structured way, attaches the invoice, and records your confirmation with its timestamp. Beyond that, whether your business-meal costs are recognised depends on the quality of your invoice, the precision of your entries, the way the document is retained, and the tax assessment. Those points remain with you and your tax adviser.

Belegomat is the bridge between the business meal and your tax adviser: a quiet helper for a clean receipt.

This article is for general information and reflects our understanding of the rules referred to. It does not constitute tax advice and gives no assurance about tax recognition in any individual case. For an assessment of your specific situation, please consult a tax adviser.