Germany E-Invoicing Exemptions: A Checklist for Every Invoice
Germany e-invoicing exemptions: invoices up to EUR 250, tickets, Kleinunternehmer, VAT-exempt supplies, B2C and foreign parties, with legal basis and 10 cases.
docutools.pro Editorial TeamEditorial TeamKey takeaways
- German e-invoicing is only mandatory when supplier and customer are both businesses established in Germany and the supply is for the customer's business.
- Invoices up to EUR 250 gross, passenger tickets and invoices from small businesses (Kleinunternehmer) may always be sent on paper or as PDF.
- Supplies that are VAT-exempt under § 4 No. 8 to 29 UStG need no invoice at all, so no e-invoice; exports and intra-EU supplies are not exempt this way.
- The EUR 250 limit refers to the total invoice amount, not to single line items, according to the Ministry of Finance letter of 15 October 2024.
- Every exemption covers issuing only: all businesses established in Germany must be able to receive e-invoices since 1 January 2025.
On this page
Germany's e-invoicing obligation covers invoices between two businesses established in Germany (§ 14(2) of the German VAT Act, UStG). The exemptions are small-amount invoices up to EUR 250 gross (§ 33 UStDV), passenger tickets (§ 34 UStDV), small businesses (§ 34a UStDV), VAT-exempt supplies under § 4 No. 8 to 29 UStG, private customers (B2C) and supplies with a foreign party.
This checklist is for finance teams, foreign suppliers and founders who need to decide per invoice whether an e-invoice is required or whether paper or PDF is still allowed. The timeline itself is covered in our guide to Germany's e-invoicing mandate; this article deals only with the exemptions.
Who needs this checklist?
The question comes up whenever one company invoices very different customers: German and foreign businesses, private individuals, associations, public bodies. Typical readers are foreign-owned subsidiaries in Germany, shared service centres that invoice for German entities, and English-speaking freelancers with mixed B2B and B2C clients.
The timing matters now. For supplies made from 1 January 2027, businesses with a total turnover above EUR 800,000 in the previous year must issue e-invoices, and from 2028 all others must follow (Section 27(38) of the German VAT Act, § 27 UStG). Our article on Germany e-invoicing 2027 shows who is affected next January. The transition periods are not exemptions in the sense of this article: they only postpone the obligation, while the exemptions are permanent.
The five-question test
Work through the questions in this order. As soon as an answer leads to "not required", you may issue an "other invoice" (sonstige Rechnung): paper, PDF or any non-structured format.
- Is the customer a business buying for its business? If not (a private person, an association acting in its non-business sphere, a public body without business activity), there is no e-invoicing obligation under § 14(2) sentence 2 No. 1 UStG.
- Are you and the customer both established in Germany? Established means a registered seat, place of management, a fixed establishment involved in the supply, or failing those a residence in Germany (§ 14(2) sentence 3 UStG). If either side is established only abroad, there is no obligation (Ministry of Finance letter of 15 October 2024, para. 16). A German VAT registration alone does not make a foreign company established.
- Is the supply VAT-exempt under § 4 No. 8 to 29 UStG? Then there is no obligation to issue any invoice, so none to issue an e-invoice. Exemptions under § 4 No. 1 to 7 UStG, such as exports and intra-EU supplies, do not count.
- Are you a small business (Kleinunternehmer) under § 19 UStG? Then § 34a UStDV lets you always issue an other invoice.
- Is the total at most EUR 250 gross, or is it a passenger ticket? Then § 33 or § 34 UStDV applies, except for reverse charge supplies under § 13b UStG (see below).
If no answer leads to an exemption, you need a structured e-invoice under EN 16931 once your transition period has ended.
The checklist: every exemption with its legal basis
| Exemption | Legal basis | Example | How to check |
|---|---|---|---|
| Customer is a private person | § 14(2) sentence 2 No. 1 UStG (covers supplies to businesses only) | Painting work in a rented flat | Customer master data: company name, VAT ID? |
| Customer is a legal entity that is not a business | § 14(2) sentence 2 No. 2 UStG; BMF letter 2024, para. 19 | Talk for an association's non-business activities | Does the customer buy for a business activity? |
| One party is established abroad | § 14(2) sentence 2 No. 1 and sentence 3 UStG; para. 16 | Consulting for a company in Vienna | Seat and involved fixed establishment of both parties |
| VAT-exempt supply under § 4 No. 8 to 29 UStG | § 14(2) sentence 2 UStG | Loans (No. 8), residential letting (No. 12), medical treatment (No. 14), school services (No. 21) | Which number of § 4 UStG applies? |
| Small business | § 34a UStDV with § 19 UStG | Designer with EUR 21,000 prior-year turnover | Prior year ≤ EUR 25,000, current year ≤ EUR 100,000 |
| Small-amount invoice | § 33 sentence 4 UStDV | Fuel receipt for EUR 89.50 gross | Total invoice amount ≤ EUR 250 including VAT |
| Passenger ticket | § 34(1) sentence 2 UStDV | Train or bus ticket | Document for passenger transport |
The wording of the three regulation sections is on gesetze-im-internet.de: § 33 UStDV (opens in a new tab), § 34 UStDV (opens in a new tab) and § 34a UStDV (opens in a new tab). Each ends with the same sentence: such an invoice "can always be transmitted as an other invoice", notwithstanding § 14(2) sentence 2 UStG.
Whether you stay below the thresholds is a quick calculation in our Kleinunternehmer calculator. What small businesses must do on the receiving side is explained in Kleinunternehmer e-invoice rules.
Ten cases from practice
In each case the issuer is a business established in Germany that does not use the small-business scheme, and the customer is Muster GmbH in Cologne unless stated otherwise.
| Case | Result | Reason |
|---|---|---|
| Fuel receipt, EUR 89.50 gross | other invoice allowed | § 33 UStDV |
| Combined office supplies invoice, EUR 260 gross | e-invoice | Total above EUR 250 (para. 23) |
| Construction work between builders under § 13b UStG, EUR 180 net | e-invoice | § 33 sentence 3 UStDV excludes § 13b |
| Train ticket for a business trip | other invoice allowed | § 34 UStDV |
| Flat let to Muster GmbH for its employees | no invoice obligation | § 4 No. 12 UStG |
| Office space let with an option to tax under § 9 UStG | e-invoice | The supply is taxable |
| Logo design by a Kleinunternehmer for Muster GmbH | other invoice allowed | § 34a UStDV |
| Consulting for a company in Vienna | no e-invoicing obligation | Customer not established in Germany (para. 16) |
| UK supplier without a German establishment invoicing Muster GmbH | no e-invoicing obligation | Supplier not established in Germany (para. 16) |
| Intra-EU supply to the EU establishment of a German business | e-invoice | § 4 No. 1 to 7 UStG is not exempt (para. 13) |
Paragraph numbers ("para.") refer to the Ministry of Finance (BMF) letter of 15 October 2024. The BMF letter of 15 October 2025 rewrote individual paragraphs, including paras. 17 and 22; the current version always prevails.
Special cases where the exemption does not help
Mixed invoices
If one invoice covers taxable supplies and supplies exempt under § 4 No. 8 to 29 UStG, the whole invoice must be an e-invoice (BMF letter 2024, para. 17). The same logic applies to the EUR 250 limit: only the total counts. Above EUR 250 an e-invoice is required, even if the part subject to the obligation is smaller (para. 23).
Recipients with their own exemption
Exemptions depend on the issuer and the supply, not on the recipient. A landlord with only VAT-exempt residential rents, or a Kleinunternehmer as customer, still receives e-invoices from suppliers (para. 17).
Business and non-business use
If a legal entity buys partly for its business and partly for its non-business sphere, the e-invoicing obligation takes priority (para. 21). For public-law entities this applies even when the business share is very small (para. 54).
Reverse charge, self-billing and special schemes
Domestic reverse charge invoices between German businesses, self-billed invoices (Gutschrift) and invoices under the special schemes of § 24, § 25 and § 25a UStG are not exempt (para. 17). For § 13b supplies, the small-amount rule does not help either, because § 33 sentence 3 UStDV excludes them.
Invoices to public authorities
The VAT exemptions do not affect obligations under other rules. Suppliers to German federal authorities must invoice electronically under the federal e-invoicing regulation (E-Rechnungsverordnung), independent of the VAT Act (para. 20).
How to document the decision
German law does not require a note on the invoice that an exemption applies. For a later tax audit, a clear record still helps:
- Maintain customer master data: store whether each customer is a business and where it is established. Under para. 15 you may rely on the customer's information if you act with the care of a prudent businessperson and have no contrary information. A VAT ID can indicate business status.
- Map tax codes: link every VAT-exempt service in your invoicing system to the specific number of § 4 UStG. The exemption note must be on the invoice anyway.
- Review small-business status every year: record prior-year and current-year turnover. If current-year turnover exceeds EUR 100,000, the exemption ends from the transaction that crosses the limit.
- Flag document types: mark small-amount invoices and tickets in bookkeeping so that combined invoices above EUR 250 stand out.
For the full list of invoice details on a normal invoice, see German invoice requirements.
How to check exemptions and invoices with docutools.pro
- Open the small-business threshold check and enter "Actual prior-year revenue (net, €)" and "Expected current-year revenue (net, €)", then click "Check now". It tests EUR 25,000 and EUR 100,000 and warns from EUR 85,000. Without a prior-year figure, for example in a founding year, it only applies the EUR 100,000 test.
- In the German invoice requirements checker, choose "Checklist" and then "Simplified invoice (≤ €250 gross)". You see the five items of § 33 UStDV and tick what the receipt contains.
- For invoices above EUR 250, choose "Full invoice (> €250 gross)" to see 13 items and check every mandatory invoice detail. The tool runs in your browser, so the file does not leave your computer. It does not check arithmetic or VAT rates.
- Exempt businesses still receive e-invoices. Load the XML file into the XRechnung viewer: it displays the invoice in readable form and checks it the way the KoSIT validator does (configuration 2026-08-31). The file is sent to our server for this. The free plan allows two uploads per day up to 500 KB; the Pro plan removes these limits.
More articles on deadlines, industries and formats are in our e-invoicing mandate guides.
Sources
- § 14 UStG (issuing invoices) (opens in a new tab)
- § 27 UStG (transition rule in para. 38) (opens in a new tab)
- § 4 UStG (VAT exemptions) (opens in a new tab)
- § 33 UStDV (opens in a new tab), § 34 UStDV (opens in a new tab), § 34a UStDV (opens in a new tab)
- BMF letter of 15 October 2025 on e-invoicing (opens in a new tab); BMF letter of 15 October 2024, BStBl I p. 1320, paras. 13 to 23 and 52 to 54
Last reviewed: October 2026
This article is general information, not tax or legal advice.
Tools for this article
- Invoice Mandatory Fields CheckerVerify all mandatory §14 UStG invoice fields via checklist or XRechnung/ZUGFeRD XML.Open tool →
- Kleinunternehmer Calculator §19 UStGCheck whether your revenue stays within Germany's 2025 small-business VAT thresholds.Open tool →
- XRechnung ViewerParse, validate & repair German e-invoices with GoBD-compliant audit trail.Open tool →
Frequently asked questions
Do foreign companies have to send e-invoices to German customers?
No, not under German VAT law. The obligation in Section 14(2) of the German VAT Act (§ 14 UStG) applies only when both the supplier and the customer are established in Germany. A supplier with no seat, management or involved fixed establishment in Germany may invoice on paper or, with the customer's consent, as PDF. Public-sector buyers can still require e-invoices under their own procurement rules.
Is the transition period until 2027 an exemption?
No. The transition rules in § 27(38) UStG only delay the obligation. Paper and PDF invoices remain allowed for supplies made in 2025 and 2026, and for supplies in 2027 only if the issuer's total turnover in 2026 was at most EUR 800,000. From 1 January 2028 that relief ends. The permanent exemptions are small-amount invoices, tickets, Kleinunternehmer invoices and supplies outside the scope.
Can an exempt business still send e-invoices?
Yes. None of the exemptions prohibits e-invoices. A Kleinunternehmer, a taxi company or a shop issuing small receipts may use XRechnung or ZUGFeRD voluntarily at any time. Sections 33, 34 and 34a of the VAT Implementing Regulation (UStDV) only allow these invoices to be sent as an other invoice instead. For invoices to private customers, any electronic format needs the recipient's consent.
Does the EUR 250 rule apply to reverse charge invoices?
Not according to the wording. § 33 sentence 3 UStDV excludes invoices for supplies under §§ 3c, 6a and 13b UStG from the small-amount rule. The relief that lets a small-amount invoice always be sent as an other invoice refers to an invoice under sentence 1. A domestic reverse charge invoice under § 13b UStG between German businesses is therefore subject to the e-invoicing obligation even below EUR 250.