E-invoices as a German small business (Kleinunternehmer)

A business using the German small-business rule (§ 19 UStG) is exempt from issuing e-invoices, according to the Federal Ministry of Finance, but must be able to receive them ^[1]. For receiving, the ministry says an email inbox is already enough ^[1].

Under § 19(1) UStG, a sale by a business resident in Germany is exempt if total turnover did not exceed 25,000 euros in the previous calendar year and does not exceed 100,000 euros in the current one ^[2]. A small business that switches to standard taxation is, according to the ministry, obliged to issue e-invoices from that point on ^[1].

Paper, PDF or e-invoice?

Under § 34a UStDV, a small business's invoice can always be sent as a "sonstige Rechnung" (any other invoice) ^[3]. § 14 UStG defines that as an invoice sent in another electronic format or on paper ^[4]. A small business that uses an e-invoice anyway may do so, according to the ministry's letter of 15 October 2025, without the recipient's consent for sales between domestic businesses ^[5].

A common reason for issuing one voluntarily is a customer whose accounts department processes incoming invoices automatically and asks for it.

What the invoice has to contain

§ 34a UStDV lists the details on a small business's invoice ^[3]. Two of them matter most for an e-invoice:

• the tax number issued by the tax office, the VAT identification number, or the small-business identification number ^[3];
• the total price with a note that the small-business exemption applies (§ 19 UStG) ^[3].

According to the ministry, small-business invoices under § 34a UStDV need not carry a sequential number ^[5]. In an XRechnung the invoice number (BT-1) is still technically mandatory: rule BR-2 of the specification requires it in every invoice ^[6].

How this looks in XRechnung and ZUGFeRD

The technical rules come from the European norm EN 16931 and KoSIT's XRechnung specification ^[6]. For a small-business invoice, three places matter:

• The exemption reason. An exempt VAT breakdown needs an exemption reason as a code (BT-121) or as text (BT-120), otherwise the check reports BR-E-10 ^[6].
• The rate. In an exempt line the VAT rate (BT-152) must be 0 according to the specification (BR-E-5) ^[6].
• The seller identifier. The tax number goes in BT-32. Rule BR-CO-26 additionally requires at least one of seller identifier (BT-29), legal registration identifier (BT-30) or VAT identifier (BT-31) ^[6]. An invoice that carries only the tax number fails this rule.

Which VAT category is right for your sales is a tax question. If in doubt, settle it with your tax adviser.

With our form

Tick "I invoice as a small business (§ 19 UStG)" in the form. Every line is then set to exempt (category E) and the § 19 UStG note is entered as the exemption reason. If you have no VAT number, the form asks for the "Business reference number" before it creates the invoice, so that BR-CO-26 is met. Every file we generate is checked with the official validator before you get it.