Kleinunternehmer E-Invoice Rules in Germany: Receive Yes, Issue No

A Kleinunternehmer e-invoice is never mandatory to issue, but receiving one is. Since 1 January 2025, German small businesses under § 19 UStG must be able to accept e-invoices. Under Section 34a sentence 4 of the VAT Implementing Ordinance (§ 34a UStDV), they may keep sending paper invoices, or PDFs with consent, with no end date, until they exceed the turnover thresholds.

This guide is for English-speaking freelancers, founders and side-business owners in Germany who use the small-business rule (Kleinunternehmerregelung). It sorts the rules by situation, shows with a worked example when the exemption ends, and explains what a voluntary e-invoice must contain. For the full timeline that applies to all businesses, see our guide to the Germany e-invoicing mandate.

Who counts as a Kleinunternehmer?

Under Section 19 (1) of the German VAT Act (§ 19 UStG) (opens in a new tab), a business established in Germany is a Kleinunternehmer if its total turnover (Gesamtumsatz) was no more than EUR 25,000 in the previous calendar year and does not exceed EUR 100,000 in the current year. Since 2025, its sales are VAT-exempt; before 2025, the VAT was simply not collected.

Three details from the BMF letter of 18 March 2025 on the small-business rule matter for e-invoicing:

• Turnover means the actual total turnover under § 19 (2) UStG, counted when payments are received. Sales of fixed assets are left out.
• In the year you start your business, the limit is EUR 25,000, not EUR 100,000 (Section 19.1 (3) UStAE).
• The sale that takes you above EUR 100,000 is already taxable (Section 19.1 (2) UStAE).

Our Kleinunternehmer calculator checks both thresholds. If you leave the prior-year field blank, it only applies the EUR 100,000 test, so in your first year compare your turnover with EUR 25,000 yourself. To decide whether opting out makes sense, see the comparison of Kleinunternehmer vs standard VAT.

What applies to you? Rules by scenario

In German law, any invoice that is not an e-invoice is a "sonstige Rechnung" (other invoice): paper, PDF or a Word file.

The last row surprises many freelancers. § 34a UStDV is a VAT rule. The federal E-Invoicing Ordinance (§ 3 ERechV) (opens in a new tab) has no small-business exemption, and the federal states have their own rules for their authorities.

What changed with the BMF letter of 15 October 2025?

The BMF letter of 18 March 2025 had stated in Section 14.7a (3) UStAE that a Kleinunternehmer could issue an e-invoice only with the customer's consent. The BMF letter of 15 October 2025 (opens in a new tab) rewrote that paragraph. In translation, it now says that issuing and sending an e-invoice "is always possible without the recipient's consent", provided the other conditions are met.

Section 14.1 (6) sentence 4 UStAE says the same for invoices to German businesses. Consent is now needed only for "another electronic format", which in practice means a PDF. Consent needs no particular form and can be given simply by accepting the invoice without objection (paragraph 22 of the letter).

The same letter confirms that Kleinunternehmer invoices do not need a sequential invoice number (Section 14.5 (14) UStAE). A unique number is still useful, because customers with e-invoicing software match payments by it.

What must a Kleinunternehmer invoice contain?

§ 34a UStDV (opens in a new tab) lists six minimum details, whether you send paper, a PDF or an e-invoice:

1. the full name and address of you and your customer,
2. your tax number (Steuernummer), VAT ID (USt-IdNr.) or small-business ID number,
3. the issue date,
4. the quantity and type of goods, or the scope and type of service,
5. the price as one total, with a note that the small-business VAT exemption under § 19 UStG applies,
6. for self-billing, the word "Gutschrift".

There is no mandatory wording for the note. Section 14.7a (1) UStAE accepts informal wording such as "steuerfreier Kleinunternehmer" if it clearly names the exemption. Clear options are:

• "VAT exemption for small businesses under § 19 UStG."
• "Steuerbefreiung für Kleinunternehmer gemäß § 19 UStG."

The older German phrase "Gemäß § 19 UStG wird keine Umsatzsteuer erhoben" ("no VAT is charged") describes the law before 2025. Update your template.

What happens when you exceed the thresholds?

The exemption from issuing e-invoices then ends, but not always at once. Two questions decide it: from which sale the standard VAT rules apply, and which transition rule in § 27 (38) UStG (opens in a new tab) covers you after that.

Worked example: a freelance developer in 2027

The fictitious freelancer Muster Dev had total turnover of EUR 22,000 in 2026. By 10 November 2027 she has received EUR 96,000. Beispiel GmbH orders a project for EUR 9,000 and pays on 20 November 2027.

If the EUR 9,000 invoice went out without VAT before the payment arrived, it must be corrected. The BMF letter of 18 March 2025 names the consequences "for invoicing, input VAT deduction and VAT returns".

The three cases at a glance

The middle row is the most common case. If you turn over EUR 30,000 in 2027, you stay a Kleinunternehmer for 2027, but from 1 January 2028 you must send e-invoices to business customers in Germany. How the EUR 800,000 test works is explained in our guide to Germany e-invoicing in 2027.

What does a voluntary e-invoice look like?

Some customers ask for an XRechnung or a ZUGFeRD file because their accounting software reads it automatically. Accepted formats are XRechnung and ZUGFeRD from version 2.0.1, except the MINIMUM and BASIC WL profiles (see our guide to ZUGFeRD profiles). Three validation rules matter for small businesses:

In an e-invoice, the exemption reason in BT-120 does the job of the mandatory note under § 34a sentence 1 no. 5 UStDV.

How to receive and create e-invoices with docutools.pro

To read and check an incoming e-invoice:

1. If you receive a ZUGFeRD PDF, open the ZUGFeRD extractor, click "Choose PDF" and then "Download XML". It runs in your browser; the file does not leave your computer.
2. Upload the XML file to the XRechnung viewer. The file is sent to our server for this. The free plan allows two uploads per day, up to 500 KB each.
3. Under "Extracted data" you see the invoice number, date, parties, totals and line items, plus the result of the "KoSIT validation": "KoSIT-conformant / Valid XRechnung" or "Not KoSIT-conformant". The viewer does not show the Leitweg-ID, IBAN or due date; open the file in the XML viewer, which also runs in your browser, to read them.
4. Keep the XML file as the original record, not just a printout. Our guide to e-invoice archiving in Germany explains the rules.

To send a voluntary e-invoice:

1. Open the generator to create an XRechnung. Single invoices need no account.
2. Under "Company", enter your VAT ID. There is no field for the tax number (BT-32). Without a VAT ID, the XRechnung fails rule BR-DE-16, so use your invoicing software instead.
3. Under "Items", in the "VAT" section, choose "Exempt" and replace the default text in "Reason for VAT exemption" with the § 19 UStG note.
4. Under "Generate & download", export a "ZUGFeRD PDF" or "XRechnung XML". The data is sent to our server for this.

For many invoices at once, the Pro plan adds CSV batch processing. More guides on obligations and exemptions are on the e-invoicing mandate topic page, and freelancers will find more in e-invoicing for freelancers.

Sources

• § 19 UStG (small-business rule) (opens in a new tab)
• § 34a UStDV (invoices of small businesses) (opens in a new tab)
• § 27 (38) UStG (transition rules) (opens in a new tab)
• BMF letter of 15 October 2025 on e-invoicing (opens in a new tab)
• BMF letter of 18 March 2025 on the small-business rule (opens in a new tab)
• § 3 E-Invoicing Ordinance (ERechV) (opens in a new tab)

Last reviewed: October 2026

This article is general information, not tax or legal advice.