Kleinunternehmer Invoice in Germany: Template, Wording and Rules

A Kleinunternehmer invoice in Germany needs at least six details under § 34a UStDV: the full names and addresses of both parties, your tax number or VAT ID, the issue date, the quantity and type of service, and one total amount with a note that the small-business exemption under § 19 UStG applies. It shows no VAT.

This guide is for English-speaking freelancers and founders in Germany who use the small-business rule (Kleinunternehmerregelung). It walks through each step, gives a full sample invoice as a table, compares note wordings in German and English, and explains what changes in an e-invoice. For invoices that do charge VAT, see our checklist of German invoice requirements.

What you need before your first invoice

Settle four points before you build a template:

• Your Kleinunternehmer status. Under Section 19 of the German VAT Act (§ 19 UStG) (opens in a new tab), your sales are VAT-exempt if your total turnover was no more than EUR 25,000 in the prior year and does not exceed EUR 100,000 in the current year. Our Kleinunternehmer calculator checks both limits.
• A tax number or VAT ID. One of them must be on every invoice. The tax number (Steuernummer) comes from your local tax office after registration; the VAT ID (USt-IdNr.) comes from the Federal Central Tax Office (BZSt).
• Your exemption note. Pick one sentence and use it on every invoice (step 5 below).
• A numbering scheme. Not required for Kleinunternehmer, but clients expect it.

Which details does § 34a UStDV require?

§ 34a of the VAT Implementing Ordinance (UStDV) (opens in a new tab) is the special rule for invoices covering VAT-exempt small-business sales. It replaces the standard list in § 14 (4) UStG for these invoices:

The invoice number and the date of supply are missing from § 34a UStDV. Include both anyway. Your client needs the number for their records, and the date decides which calendar year a sale counts toward for the § 19 UStG limits.

Step by step: writing the invoice

1. Add your details. Your full legal name (for a sole trader, first and last name) and address. A business name on its own is not enough.
2. Add your client. Full name and address. Abbreviations are allowed under § 31 UStDV (opens in a new tab) if both parties can be clearly identified.
3. Add your tax number or VAT ID. Many freelancers use the VAT ID when they have one, because it reveals less about their personal tax file.
4. Add date, number and service. Issue date, invoice number, and the quantity and type of service, for example „3 hours business card layout, September 2026“.
5. State one total and add the note. No VAT rate, no VAT amount, no line „plus VAT“. Put the § 19 UStG note directly below the total.
6. Add payment details. Bank details and a due date are not required by tax law, but every invoice you want paid should have them.
7. Choose how to send it. Paper or PDF is always permitted for Kleinunternehmer under § 34a sentence 4 UStDV. A PDF sent by email needs the client's consent, which can be implied.

Result: an invoice that meets § 34a UStDV and does not prompt VAT questions from your client.

Sample invoice as a table

The fictitious designer Muster Design invoices Beispiel GmbH for a logo and a business card layout. All data is invented.

The rows for invoice number, service period and payment go beyond § 34a UStDV. They are voluntary, and still worth including.

Variant: small-amount invoice up to EUR 250

If the total is EUR 250 or less, § 33 UStDV (opens in a new tab) allows a simplified invoice (Kleinbetragsrechnung): your name and address, issue date, quantity and type of service, and one total. The client's details and your tax number can be left out. § 33 sentence 1 no. 4 UStDV still requires the note on the exemption. An invoice for the business card layout alone (EUR 180.00) would show Muster Design with address, the date, „3 hours business card layout“, EUR 180.00 and the § 19 UStG note.

Variant: self-billing by the client

If your client issues the invoice for your service, for example a platform or a publisher, the document must carry the word „Gutschrift“ under § 34a sentence 1 no. 6 UStDV. Check that it contains the § 19 UStG note and shows no VAT. If it does show VAT, object to it; under § 14 (2) UStG the self-billed invoice then stops counting as an invoice.

How should the § 19 UStG note be worded?

There is no mandatory wording. § 34a sentence 1 no. 5 UStDV only requires a note that the small-business exemption under § 19 UStG applies. The table rates common versions:

Invoices in English are fine: German tax law sets no invoice language. Under § 87 of the German Fiscal Code (AO) (opens in a new tab), the tax office may ask for a translation of foreign-language documents, which is one more reason to keep the German note on the invoice.

Common mistakes and how to fix them

On the first mistake: according to the BMF letter of 18 March 2025 (opens in a new tab) (para. 5), a Kleinunternehmer does not owe VAT shown on an invoice to a private consumer. For invoices to businesses, you owe it under § 14c (1) UStG (opens in a new tab) until you correct it.

What about e-invoices for Kleinunternehmer?

You never have to issue them: § 34a sentence 4 UStDV permanently allows Kleinunternehmer to send paper or PDF invoices. Since 2025 you must be able to receive e-invoices, though. Our guide to Kleinunternehmer e-invoice rules covers the details.

If a client asks for an XRechnung or ZUGFeRD file anyway, you express the small-business rule through the VAT category. These EN 16931 rules are reported as errors in a KoSIT check if broken:

This is the VAT breakdown in a UBL XRechnung (excerpt, abridged):

<cac:TaxTotal>
  <cbc:TaxAmount currencyID="EUR">0.00</cbc:TaxAmount>
  <cac:TaxSubtotal>
    <cbc:TaxableAmount currencyID="EUR">1080.00</cbc:TaxableAmount>
    <cbc:TaxAmount currencyID="EUR">0.00</cbc:TaxAmount>
    <cac:TaxCategory>
      <cbc:ID>E</cbc:ID>
      <cbc:Percent>0</cbc:Percent>
      <cbc:TaxExemptionReason>Steuerbefreiung für Kleinunternehmer gemäß § 19 UStG</cbc:TaxExemptionReason>
      <cac:TaxScheme>
        <cbc:ID>VAT</cbc:ID>
      </cac:TaxScheme>
    </cac:TaxCategory>
  </cac:TaxSubtotal>
</cac:TaxTotal>

The element cbc:TaxExemptionReason is BT-120. In an e-invoice it carries the note that § 34a sentence 1 no. 5 UStDV requires. For a complete file explained field by field, see our e-invoice example for Germany.

How to write and check a Kleinunternehmer invoice with docutools.pro

Check your status:

1. Open the small-business threshold calculator. It runs in your browser; your figures stay on your computer.
2. Enter „Actual prior-year revenue (net, €)“ and „Expected current-year revenue (net, €)“ and click „Check now“. Leave the prior year blank in your founding year: the calculator then checks against EUR 25,000 instead of EUR 100,000. From EUR 85,000 in the current year it shows a warning.

Check a paper or PDF invoice:

1. Open the German invoice requirements checker in „Checklist“ mode and choose „Full invoice (> €250 gross)“.
2. Tick the details your invoice has, including the exemption note, and click „Check mandatory fields“. The list follows § 14 (4) UStG, so VAT rate and VAT amount stay unticked on a Kleinunternehmer invoice and it will not reach 100 %. What matters is that only these two items appear under „Missing fields“.

Create a voluntary e-invoice:

1. Open the generator to create an XRechnung. Single invoices need no account; your data is sent to our server to build the file.
2. Under „Company“, enter your „VAT ID“. There is no field for the tax number; without a VAT ID the file breaks BR-DE-16, so use invoicing software instead.
3. Under „Items“, choose „Exempt“ as the VAT treatment and replace the default text in „Reason for VAT exemption“ with your § 19 UStG note.
4. Under „Generate & download“, export „ZUGFeRD PDF“ or „XRechnung XML“. The generator has no dedicated Kleinunternehmer option; „Exempt“ produces category E at 0 %.

CSV batch processing for many invoices is part of the Pro plan.

Checks after you are done

• Does the invoice show no VAT rate and no VAT amount, not even „0 %“?
• Is the § 19 UStG note close to the total?
• Is the tax number or VAT ID correct?
• Is your current-year turnover, including this invoice, still at or below EUR 100,000?

More guides on templates and processes are on the invoicing in Germany hub. If you are looking for a free tool to issue invoices, see our overview of free e-invoicing software for Germany.

Sources

• § 19 UStG (small-business exemption) (opens in a new tab)
• § 34a UStDV (invoices of small businesses) (opens in a new tab)
• § 33 UStDV (small-amount invoices) (opens in a new tab)
• § 14c UStG (incorrect or unauthorised VAT statement) (opens in a new tab)
• § 87 AO (official language) (opens in a new tab)
• BMF letter of 18 March 2025 on the small-business scheme (opens in a new tab)

Last reviewed: October 2026

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