EC sales list (Zusammenfassende Meldung, ZM) in Germany: who, what, by when – step by step

What is the EC sales list?

The EC sales list (Zusammenfassende Meldung, ZM) is a list of your VAT-exempt or, in Germany, non-taxable sales to businesses in other EU countries, sorted by their VAT identification number (USt-IdNr.). The legal basis is § 18a UStG. It goes not to your tax office (Finanzamt) but to the Federal Central Tax Office (Bundeszentralamt für Steuern, BZSt).

The purpose: if you write an invoice without German VAT to a client in Austria, the client must pay tax on the transaction in Austria. Via the European VAT Information Exchange System (VIES) the BZSt passes your details to the Austrian tax administration, which checks whether the client has also declared the transaction there. The ZM is therefore the control instrument for the reverse charge procedure and VAT-free intra-Community supplies.

Who must file an EC sales list – and who does not?

Every business that had at least one of the following transactions in a reporting period must file. The amount does not matter: a single invoice for €300 to an agency in Spain triggers the ZM for that quarter.

You do not have to file the ZM if you use the small business scheme (Kleinunternehmerregelung) (§ 18a Abs. 4 UStG). Sales to clients in non-EU countries such as Switzerland, the United Kingdom or the USA, sales to private individuals and your purchases from abroad do not belong in the ZM either. If you had no reportable transactions in a quarter, you do not file a ZM for that quarter.

• Intra-Community supplies: goods go to a business with a VAT ID in another EU country (code L).
• Other services under § 3a Abs. 2 UStG to businesses in other EU countries for which the client owes the tax – i.e. almost all services such as programming, design, consulting, translation or marketing (code S).
• Supplies as the first purchaser in an intra-Community triangular transaction (code D).
• Intra-Community transfers of your own goods and transactions in a call-off stock under § 6b UStG.

Which details go into the EC sales list?

The ZM is short: there is one line for each client. You do not report individual invoices, but the total tax base (net amounts) in the reporting period per VAT ID and type of transaction, in whole euros. If you both supplied goods and provided services to the same client, there are two lines – one with L, one with S.

The client’s correct VAT ID, including the country code (such as ATU12345678 or NL123456789B01), is crucial. Have it confirmed by the BZSt in a qualified check, i.e. with name and address matching, before the first invoice. A wrong or invalid number leads to queries and can cost you the tax exemption on supplies of goods.

Timing: you report services for the period in which you performed them. You report intra-Community supplies for the period in which you issued the invoice, at the latest for the period of the month following the supply. Convert invoices in foreign currency into euros.

Deadlines: monthly or quarterly?

The ZM must be filed by the 25th day after the end of the reporting period. If the 25th falls on a weekend or public holiday, the deadline moves to the next working day. Unlike the VAT return (Umsatzsteuer-Voranmeldung), there is no permanent filing extension (Dauerfristverlängerung): even if your VAT return is only due one month later, the ZM deadline stays on the 25th.

The reporting period depends on your supplies of goods. If you only provide services, you always report quarterly. For supplies of goods (including triangular transactions) the quarter is only allowed if the total in the current quarter and in each of the four preceding quarters does not exceed €50,000. If you exceed €50,000 during a quarter, you file monthly reports from the month in which you exceed it; the ZM for that month then also covers the previous months of the quarter.

There is a special rule for very small businesses: if you are exempt from filing VAT returns, your revenue was at most €200,000 and your EU sales at most €15,000, an annual ZM by 25 January of the following year may be enough (§ 18a Abs. 9 UStG).

Worked example: ZM for Q3 2026

Tomás is a self-employed software developer in Munich and also sells measuring devices he builds himself. In Q3 2026 he wrote three invoices of €3,500 each to an agency in Rotterdam (July, August, September), an invoice of €2,400 to a client in Vienna, to whom he issues a €400 credit note for a discount in September, and supplied measuring devices for €1,250 to a laboratory in Brussels. He also billed consulting for €1,800 to a company in Zurich.

The Zurich invoice does not go into the ZM (non-EU country, Kz 45). The credit note reduces the tax base in the quarter in which it was issued. The ZM is due on 26 October 2026. In the three VAT returns for July to September, Kz 21 must total €12,500 and Kz 41 €1,250 – exactly as in the ZM.

How to file the ZM via ELSTER or the BZSt

The ZM must be submitted electronically; paper is only allowed on application in cases of hardship. Most self-employed people use their existing ELSTER account for this. Businesses not registered for tax in Germany and bulk filers use the BZStOnline portal.

• In Mein ELSTER, open the form “Zusammenfassende Meldung” for the reporting period under “Formulare & Leistungen”.
• Enter your own VAT ID and the reporting period (month or quarter).
• Enter one line per client with country code, VAT ID, total in whole euros and type (L, S or D).
• Check and send; save the transmission log with the transfer ticket.
• Compare the totals with Kennzahlen 21, 41 and 42 of your VAT returns for the same period.

Correcting the ZM: deadline and procedure

If you later find that a ZM you filed is wrong or incomplete, you must correct it within one month (§ 18a Abs. 10 UStG). The original report for the period concerned is corrected – so you do not simply include the error in the next ZM. In ELSTER you choose the correction for the same reporting period and report the affected line again with the correct amount.

It is different if the tax base changes later, for example through a credit note, an early-payment discount, a cancellation invoice or a bad debt: you report this change in the period in which it occurs, like the credit note to the Viennese client in the example above. If this also changes the VAT return, you adjust both.

What happens if the ZM is late or missing?

There is no late filing penalty for the ZM as there is for tax returns, because § 152 AO expressly does not apply. But a missing or wrong ZM is not without consequences. Possible consequences:

• A fine of up to €5,000 if you intentionally or recklessly fail to file the ZM, file it incorrectly, incompletely or late, or fail to correct it in time (§ 26a UStG).
• A coercive fine (Zwangsgeld) with which the BZSt can enforce filing.
• For supplies of goods: loss of the tax exemption. An intra-Community supply is only VAT-exempt if you filed the ZM correctly and completely (§ 4 Nr. 1 Buchst. b UStG). In the worst case you then owe 19 % German VAT on the supply.
• Queries from the tax office if the figures do not match your VAT return or the details your clients report in their country.

Matching with the VAT return

The ZM and the VAT return describe the same transactions from two angles. The tax office compares them automatically, and discrepancies quickly lead to a letter. Check this assignment before every filing:

The ZM with Kontelio

Kontelio compiles the ZM for each quarter from your booked invoices: one line per client with country, VAT ID and the amounts for supplies of goods (L) and other services (S). Clicking an amount shows the invoices behind it. The figures come from the same entries as the VAT return and the annual VAT return, so Kz 21 and Kz 41 match the ZM. On the Business and Pro plans Kontelio checks the ZM with the official ELSTER software and sends it directly to ELSTER.

You check your clients’ VAT IDs directly with the BZSt; if one is not confirmed, Kontelio points this out when you create the invoice. The ZM only appears in deadlines and obligations for periods with such transactions. Kontelio does not support monthly ZMs required because of supplies of goods over €50,000. More about the VAT features on the page VAT with Kontelio.

Frequently asked questions