German Kleinunternehmer: which e-invoice duties apply?

Small business is a tax status here

Businesses making supplies exempt under Germany’s section 19 UStG Kleinunternehmer scheme are exempt from mandatory e-invoice issuance for those invoices. They must nevertheless be able to receive incoming e-invoices. That receiving task does not wait until 2028. The official tax-office overview explains both the exemption and the receiving readiness required since 2025.

Here, “Kleinunternehmer” refers to a specific VAT status. It does not simply mean a business with few employees or a company that describes itself as small. A small business charging ordinary VAT may therefore face different issuance requirements from a business making supplies under the scheme. Establish your status from your tax records before relying on the exemption.

The €800,000 threshold is a different rule: it concerns a temporary extension for 2027. The turnover-threshold article explains that distinction. The end of that transition does not automatically remove the separate Kleinunternehmer exemption.

Issuing and receiving at a glance

The following summary assumes the Kleinunternehmer status described above. Public-sector customers and special circumstances may bring additional requirements that need a separate check.

The tax authority identifies section 34a UStDV as the basis for the issuance exemption. Exemption from a structured format does not remove every other invoice requirement. Check the required particulars and exemption wording for your particular invoice. The official explanation provides the starting point for that assessment.

Set up a simple receiving process

An email mailbox is generally enough as a receiving channel. A dedicated portal is not universally required just to receive an e-invoice. Downloads and agreed electronic interfaces are other possibilities, as explained in the tax authority’s receiving guidance.

Use a short checklist to make sure the file survives the next steps:

1. Assign somebody to check the invoice mailbox regularly.
2. Save the original attachment or downloaded original file.
3. Use a suitable tool to make XML invoice data readable.
4. Compare the supplier, goods or services, and amounts with the order and delivery.
5. Ask the issuer for a corrected file when needed, preserving its relationship to the original.

A supplier does not have to replace a structured invoice with a simple PDF merely because you cannot yet read XML. Prepare how you will read the data and pass it to bookkeeping. Technical validation can support that process, but it does not replace the business check against the actual transaction.

If you choose to issue structured invoices

Some customers already request XRechnung or a hybrid ZUGFeRD file. Voluntary structured invoicing may simplify a shared workflow. Confirm the format, accepted profile and customer reference before exporting. The distinction between structured e-invoices and other invoices is established in section 14(1) UStG.

Choosing a format does not establish your VAT treatment. Ensure tax information and exemption wording match the actual supply. A technical validator cannot determine whether you qualify for the Kleinunternehmer scheme or whether the customer received the goods or services.

Use the tools for the right task

FakturFokus’s public XRechnung check inspects supported files in your browser. The ZUGFeRD check addresses hybrid files; read its limitations, particularly the lack of complete PDF/A validation in the browser.

For outgoing invoices, use the format guide and creation instructions. Download needed files from the workspace before they expire. The retention article explains why temporary product storage does not replace your long-term invoice records.