German Kleinunternehmer do not have to issue e-invoices: section 34a UStDV lets them always send an ordinary invoice, on paper or as a PDF, and this exemption is not time-limited. But since 1 January 2025 they must be able to receive e-invoices, and invoices to public bodies follow separate rules. This page explains what applies, with the official sources. It is general information, not tax advice.
Who is a Kleinunternehmer?
A business established in Germany whose total turnover did not exceed EUR 25,000 in the previous calendar year and does not exceed EUR 100,000 in the current one, and which has not opted out (section 19 UStG). It charges no VAT, and its invoices must say that the small business exemption applies (section 34a UStDV).
What applies to a Kleinunternehmer?
| Applies? | Source | |
|---|---|---|
| Receiving e-invoices from other businesses | yes, since 1 January 2025 | BMF FAQ, question 12 |
| Issuing e-invoices to other businesses | no, an ordinary invoice is always allowed | section 34a UStDV; BMF FAQ, question 4 |
| Invoices to federal public bodies | electronic; only direct orders up to EUR 1,000 are exempt | section 3 ERechV; BMF FAQ, question 4a |
| After switching to standard VAT | the general rules, including issuing e-invoices | BMF FAQ, question 4 |
Do not confuse the exemption with the transition period
All businesses may still send ordinary invoices until the end of 2026, and businesses with previous-year turnover of up to EUR 800,000 until the end of 2027 (BMF FAQ, question 11). That is a transition period for everyone. The Kleinunternehmer exemption is separate and has no end date.
How do I receive e-invoices?
An email inbox is enough to receive them (BMF FAQ, question 12). An e-invoice is a structured file, usually XRechnung XML or a ZUGFeRD PDF. A ZUGFeRD PDF shows a readable page; an XRechnung file needs software to read. Klarbon's e-invoice viewer shows either as a readable invoice in your browser, free. The original file is the e-invoice and must be kept, not only a printout.
Should I send e-invoices anyway?
You may. Some customers prefer them because their software reads the data. If a public body requires XRechnung, you need one regardless. Klarbon can check an e-invoice you received or created. When you create one, remember that an invoice under section 19 UStG carries no VAT and must state the exemption.
Related
Frequently asked questions
Do Kleinunternehmer have to send e-invoices in Germany?
No. Under section 34a UStDV, an invoice for turnover exempt under section 19 UStG can always be sent as another kind of invoice, such as paper or a PDF. This exemption is not time-limited.
Do Kleinunternehmer have to receive e-invoices?
Yes. Since 1 January 2025 every business established in Germany must be able to receive e-invoices, Kleinunternehmer included. An email inbox is enough to receive them.
Is the EUR 800,000 threshold the Kleinunternehmer rule?
No. EUR 800,000 of previous-year turnover is the limit for the longer transition period to the end of 2027. The Kleinunternehmer limits are EUR 25,000 in the previous year and EUR 100,000 in the current year.
Do Kleinunternehmer need XRechnung for public bodies?
Often, yes. Invoices to federal bodies follow the E-Rechnungsverordnung, which requires electronic invoices except for direct orders up to EUR 1,000 and has no Kleinunternehmer exemption. The federal states have their own rules.
Sources
- German Federal Ministry of Finance (BMF), FAQ on e-invoicing bundesfinanzministerium.de
- Section 19 UStG, small business taxation gesetze-im-internet.de
- Section 34a UStDV, invoices of small businesses gesetze-im-internet.de
- Section 3 ERechV, electronic invoices to federal bodies gesetze-im-internet.de