E-invoicing for Kleinunternehmer in Germany: what applies in 2026?

Kleinunternehmer must be able to receive e-invoices. They do not have to issue an e-invoice for supplies exempt under section 19(1) UStG—even when the general deadlines in 2027 and 2028 arrive. Paper invoices remain possible; plain PDFs may be sent electronically with recipient consent, while compliant e-invoices can be used voluntarily.

View an e-invoice

Quick answer: receiving, issuing, PDFs, and retention

Question	Short answer	What to do in practice
Must I be able to receive e-invoices?	Yes, since 1 January 2025.	Provide a reliable receiving channel, make incoming XML readable, and retain the structured original.
Must I issue e-invoices for section 19 supplies?	No. Under current law, section 34a UStDV exempts section 19 supplies from mandatory e-invoice issuance.	Paper remains possible. A plain PDF requires the recipient’s consent; a compliant e-invoice can be used voluntarily.
Does the exemption from mandatory e-invoice issuance end in 2027 or 2028?	No. It has no statutory end date under current law.	The deadlines do not replace section 34a UStDV. Reassess only if section 19 stops applying or another rule or contract governs.
How long must invoices be retained?	Generally eight years for VAT purposes.	Keep the original structured file intact and machine-readable; other bookkeeping duties can require more.

Last materially reviewed: 11 August 2026. Checked against the BMF FAQ as of March 2026, current administrative guidance, and the current statutory text.

This guide provides general information and is not legal or tax advice. Whether section 19 applies must be assessed for the specific business and transaction.

Who counts as a Kleinunternehmer
What applies in 2026, 2027, and 2028
How to receive, read, check, and retain e-invoices
Paper, PDF, XRechnung, and ZUGFeRD
Mandatory fields under section 34a UStDV
Practical examples
What changes under regular VAT taxation
Public authorities, contracts, and foreign customers
Practical checklist
Official sources
Frequently asked questions

Who is a Kleinunternehmer under section 19 UStG?

“Kleinunternehmer” is a VAT status under German law, not a legal form or a label for every small business. It can apply to freelancers, sole traders, partnerships, and GmbHs, whether the activity is full-time or a side business; none is automatically a Kleinunternehmer merely because it is small. A Kleingewerbe is a different concept.

For an established domestic business, section 19 generally applies when actual total turnover did not exceed EUR 25,000 in the previous calendar year and does not exceed EUR 100,000 in the current year. Total turnover is a VAT measure based broadly on consideration received, not simply the value of invoices issued.

In the year a business starts, the relevant actual current-year limit is EUR 25,000.
If the current-year limit is exceeded, the transaction that takes total turnover over the limit and subsequent transactions are subject to the ordinary VAT rules; earlier section 19 supplies remain exempt.
If the previous-year limit was exceeded, regular VAT taxation generally applies from the beginning of the following year.

The EUR 800,000 figure belongs to a separate e-invoice transition rule. It does not determine whether a business is a Kleinunternehmer. Read how the 2027 transition test works.

What applies in 2026, 2027, and 2028?

Section 34a UStDV currently sets no statutory end date for this exception. It is separate from the temporary transition rules that expire at the end of 2026 or 2027.

Year	Receiving	Issuing for section 19 supplies	Paper or plain PDF
2026	Required	No mandatory e-invoice format	Permitted; an electronically sent PDF requires recipient consent
2027	Required	No mandatory e-invoice format	Permitted; while section 19 applies, the EUR 800,000 transition test does not apply, but an electronically sent PDF still needs recipient consent
2028	Required	Still exempt under section 34a UStDV	Still permitted for section 19 supplies; electronic PDF needs recipient consent

These answers concern supplies that are actually exempt under section 19. A public-procurement rule, a contract, a foreign rule, or a change to regular VAT taxation can produce a different result.

Receiving an e-invoice as a Kleinunternehmer

Since 1 January 2025, domestic businesses must be able to receive e-invoices. There is no receiving exemption for Kleinunternehmer. An ordinary email inbox is sufficient to meet this requirement; a dedicated invoice address is not required.

Do I need special software or a government portal?

You do not need a dedicated inbox, central government portal, or paid accounting system merely to receive e-invoices. You do need a viewer for XRechnung XML and a suitable process to retain the structured original. E-Rechnungs-Studio’s viewer and validator are currently free, require no account, and have no monthly limit.

The tax administration also provides a free ELSTER e-invoice viewer.

Agree on a reliable receiving channel with suppliers—for example, an email address, portal, or interface.
Make XRechnung XML readable with a viewer. A compliant ZUGFeRD invoice includes a readable PDF, but its structured XML is decisive if the two representations differ.
Technical validation can identify format and business-rule errors. It does not prove that the supplier, bank details, transaction, or amounts are factually correct.
Fully automated downstream processing is not mandatory, but the structured invoice must remain accessible and readable.

A recipient who cannot or will not accept an e-invoice has no general tax-law right to demand paper or PDF instead when the supplier must issue an e-invoice.

View an e-invoice Run a technical check

Retain the structured original—not only a printout

Incoming invoices and copies of outgoing invoices generally have an eight-year VAT retention period, beginning at the end of the calendar year in which the invoice was issued. For an e-invoice, at least the structured component must remain intact, machine-readable, and in its original form. Keeping the complete original file is the safest approach, especially for a hybrid invoice with attachments or additional information.

Other tax, commercial, and GoBD duties may require additional records or controls. E-Rechnungs-Studio is a viewer, validator, and converter; it is not an invoice archive.

Does receiving an e-invoice allow me to deduct input VAT?

No. The invoice format does not change your Kleinunternehmer status. Input VAT on purchases used for supplies exempt under section 19 UStG is generally not deductible. Special adjustment rules can apply when moving to regular VAT taxation.

Sending paper, PDF, XRechnung, or ZUGFeRD

The format exception does not remove the underlying duty to issue an invoice where tax law requires one. It means that an invoice for a section 19 supply does not have to use the mandatory e-invoice format.

Format	Invoice classification	Recipient consent for domestic B2B	Practical note
Paper	Other invoice	No recipient consent needed	Permitted for section 19 supplies, unless another rule or contract requires a structured format.
Plain PDF by email	Electronic other invoice, not an e-invoice	Required; no special form is prescribed	Consent may be express, implied—for example by acceptance without objection—or given afterwards.
Compliant XRechnung or qualifying ZUGFeRD	E-invoice	Not required for a transaction between domestic businesses	Voluntary use is possible, but format, delivery channel, and buyer references should still be coordinated.

XRechnung is structured XML. Suitable ZUGFeRD profiles from version 2.0.1 combine PDF/A-3 with embedded EN 16931 XML. The ZUGFeRD MINIMUM and BASIC-WL profiles do not meet the German mandate’s format requirements. Compare XRechnung and ZUGFeRD.

A Word or Excel file—and a plain PDF generated from one—is not an e-invoice because it lacks structured invoice data. For a section 19 supply, it may still be used as an “other invoice” under the consent rules above.

The no-consent rule for a voluntary compliant e-invoice described above concerns transactions between domestic businesses. For private customers or a transaction involving a non-domestic party, consent and other national rules must be checked separately.

How can I create a voluntary e-invoice as a Kleinunternehmer?

Gather the section 34a invoice fields and any buyer reference, order number, payment details, or portal fields the customer requires.
Create a qualifying XRechnung or ZUGFeRD file. If you convert an existing PDF, review every extracted value instead of assuming it is correct.
Inspect and technically validate the structured data. Every VAT-required field must be in the XML; an unstructured attachment can supplement, but not replace, those fields.
Coordinate the delivery channel and references, then retain the complete structured file that was sent and, where useful, its validation report.

Convert an existing PDF invoice

What must a Kleinunternehmer invoice contain?

Section 34a UStDV provides a simplified list of statutory minimum fields for an ordinary Kleinunternehmer invoice:

The full names and addresses of the supplier and recipient.
The supplier’s tax number, VAT ID, or Kleinunternehmer ID.
The invoice issue date.
The quantity and customary description of goods, or the scope and type of service.
The total consideration and a clear statement that the supply is VAT-exempt under section 19 UStG.
The word “Gutschrift” when the recipient or its appointed third party issues the invoice under an agreed self-billing process.

Example exemption statement: “This supply is VAT-exempt under Germany’s Kleinunternehmer regime pursuant to section 19 UStG.”

Do not state “0% VAT” or separately show VAT. Section 19 is a VAT exemption, not a zero rate; incorrectly stated VAT can become payable.

A sequential invoice number and supply date are not among the six section 34a minimum categories. They can still be useful or required for other records. A voluntary XRechnung or ZUGFeRD invoice also has additional technical mandatory fields. Every VAT-required field must be present in the structured data; merely pointing to an unstructured attachment is not enough, although attachments may supplement the XML. The six tax minimums alone therefore do not guarantee successful EN 16931 validation or portal acceptance.

Separate simplified requirements apply to small-value invoices up to and including EUR 250 gross under section 33 UStDV and passenger transport tickets under section 34 UStDV.

Three practical examples

Example	What applies
A freelance designer using section 19 receives an XRechnung from a German supplier.	The XML file must be received and retained. A viewer makes it readable; receiving it does not require the designer to start issuing XRechnungen.
The designer emails a EUR 900 plain PDF invoice to a German business customer.	The PDF can be used for the section 19 supply, but the customer must agree to that electronic format. A compliant voluntary e-invoice does not require that consent.
A small GmbH has EUR 300,000 annual turnover but does not use the section 19 exemption.	It is not a Kleinunternehmer merely because it is small. The general mandate and the separate EUR 800,000 transition test must be checked.

What changes when section 19 no longer applies?

Once the Kleinunternehmer exemption stops applying, the ordinary VAT and e-invoice rules must be reassessed from that point. That can happen because a turnover limit is exceeded or because the business waives section 19 and opts for regular VAT taxation.

Exceeding the EUR 100,000 current-year limit ends the exemption for the transaction that takes total turnover over the limit and for later transactions.
Exceeding the EUR 25,000 previous-year limit generally means regular VAT taxation from the start of the next year.
A voluntary waiver applies from the beginning of the selected tax period and generally binds the business for at least five calendar years.

Leaving section 19 does not always mean that an e-invoice is due the same day. The underlying supply, both parties, the applicable general transition date, and other statutory exceptions still matter. Check the complete German mandate timeline.

Public authorities, contracts, and foreign customers

Invoices to public authorities (B2G)

The section 34a VAT exception does not override separate public procurement rules. Depending on the public authority and contract, XRechnung or another EN 16931 format, a portal, a Leitweg-ID, buyer references, or other fields may be required. Federal, state, and municipal rules are not identical, so check the ordering authority’s instructions.

Customer and contract requirements

A business customer can make a structured format, delivery channel, or buyer reference a contractual or operational condition. That does not turn the requirement into a statutory VAT mandate, but ignoring it can still lead to rejection or delayed payment.

Foreign customers and suppliers

Germany’s domestic B2B mandate applies only when both businesses are established in Germany for these VAT purposes. A German VAT registration alone does not necessarily make a foreign business established in Germany. Foreign e-invoice rules, place-of-supply rules, contracts, and the EU small-business scheme may still apply, so cross-border cases need a separate check.

Practical checklist for Kleinunternehmer

Confirm that section 19 applies to the particular supply.
Give suppliers a monitored address or agreed receiving channel.
Know how to display XRechnung XML and the structured part of ZUGFeRD.
Check technical results and the invoice’s factual details before paying.
Preserve the complete original file and related tax-relevant documents.
Ask customers which format, channel, and references they expect.
Obtain the recipient’s consent before sending a plain PDF electronically.
Reassess VAT status and the general e-invoice mandate when turnover or taxation changes.

Official sources

Frequently asked questions

Do Kleinunternehmer have to be able to receive e-invoices?

Yes. Since 1 January 2025, domestic businesses using the Kleinunternehmer regime have had to be able to receive e-invoices. An ordinary email inbox is sufficient; automated downstream processing is not required. Incoming structured invoices must still be made readable and retained properly.

Must Kleinunternehmer issue e-invoices in 2026, 2027, or 2028?

For supplies exempt under section 19(1) UStG, section 34a UStDV removes the mandatory e-invoice format. That statutory exception does not end merely because the 2027 or 2028 deadlines arrive. If the Kleinunternehmer regime ceases to apply, the general rules, transition dates, and other exceptions must be reassessed from that point.

Can Kleinunternehmer continue sending PDF invoices?

Yes. An ‘other invoice’ may still be issued for a supply exempt under section 19 UStG. Paper is possible. A plain PDF is not an e-invoice and may be sent electronically only with recipient consent. Consent may be express, implied—for example by acceptance without objection—or given afterwards.

Does a voluntary e-invoice from a Kleinunternehmer require recipient consent?

For a transaction between domestic businesses, a compliant e-invoice may be issued and transmitted voluntarily without recipient consent. The format, delivery channel, and buyer references should still be coordinated. Different consent requirements or foreign rules apply to private customers and cross-border cases.

How do Kleinunternehmer, Kleingewerbe, and the EUR 800,000 threshold differ?

Kleinunternehmer is a VAT status under section 19 UStG. For an established domestic business, it generally requires no more than EUR 25,000 total turnover in the previous year and no more than EUR 100,000 in the current year. Kleingewerbe is a different concept. The EUR 800,000 figure belongs only to the 2027 e-invoice transition and is not a Kleinunternehmer limit.

What mandatory information must a Kleinunternehmer invoice contain?

Section 34a UStDV generally requires the parties’ names and addresses, the supplier’s tax number, VAT identification number, or Kleinunternehmer identification number, issue date, the quantity and customary description of goods or the scope and type of service, total consideration with a reference to the section 19 VAT exemption, and ‘Gutschrift’ for self-billing. A voluntary XRechnung or ZUGFeRD invoice has additional technical mandatory fields. Separate simplified rules under sections 33 and 34 UStDV apply to small-value invoices up to and including EUR 250 gross and passenger transport tickets.

Do I need a VAT ID to issue a Kleinunternehmer e-invoice?

Not merely because the invoice is electronic. To meet the tax-law minimum requirements in section 34a UStDV, the supplier may provide its tax number, VAT identification number, or Kleinunternehmer identification number. A chosen format, buyer portal, cross-border transaction, or customer can still require additional identifiers.

Can I deduct input VAT from an e-invoice I receive?

Not merely because of the invoice format. Receiving an e-invoice does not change your Kleinunternehmer status. Input VAT on purchases used for supplies exempt under section 19 UStG is generally not deductible. Special transition and adjustment rules can apply when moving to regular VAT taxation.

How long must Kleinunternehmer retain e-invoices?

The VAT retention period for invoices is generally eight years, beginning at the end of the calendar year in which the invoice was issued. At least the structured original component of an e-invoice must remain intact and machine-readable. Other tax or commercial duties may cover additional documents or longer periods.

What applies when a Kleinunternehmer invoices a public authority?

Procurement and contractual rules apply alongside VAT law. Regardless of section 34a UStDV, a public authority can therefore require XRechnung or another EN 16931 format, a portal, a Leitweg-ID, and further references. Requirements vary by federal, state, or municipal authority and by individual contract.