E-invoices for small businesses under § 19 UStG
As a small business under § 19 UStG (the German small-business scheme, Kleinunternehmer), you do not have to issue e-invoices — but you have had to be able to receive them since 2025. And if a business customer asks for one anyway, you can create it here in a few minutes: with the correct tax exemption note in the XML, free until 31 December 2026.
- Issuing: voluntary
- Receiving: mandatory since 2025
- § 19 UStG correctly coded in the XML
- Free until 31 Dec 2026
What applies to small businesses
| Small businesses (Kleinunternehmer) | All other businesses | |
|---|---|---|
| Receiving e-invoices | Mandatory since 1 January 2025 | Mandatory since 1 January 2025 |
| Issuing e-invoices | Not mandatory — permanently | From 2027 (over €800,000 prior-year turnover) or 2028 |
| Paper and plain PDF | Remain permitted | Only during the transition periods |
The exemption from issuing is set out in § 34a UStDV (German VAT Implementing Regulation) and has no end date. You still have to receive them: a supplier who sends you an e-invoice is allowed to do so, and you must be able to accept it and store it in readable form. An email inbox is enough for that.
Who counts as a small business — the thresholds since 2025
Since 1 January 2025, new thresholds apply under § 19 UStG (German VAT Act):
- Total turnover in the previous year of no more than €25,000 and
- in the current year of no more than €100,000.
The second threshold takes effect immediately: if it is exceeded during the current year, you are subject to standard VAT from the transaction that crosses it — and then the normal e-invoicing mandate also applies to you. Also since 2025, small-business sales are explicitly VAT-exempt; before that, the wording was that the tax was "not levied".
Why an e-invoice can still make sense
Larger business customers are switching their accounting to e-invoices and asking suppliers to follow suit. Their software reads a ZUGFeRD file directly.
If you exceed €100,000 in the current year, you are immediately subject to standard VAT. If you are already writing e-invoices by then, there is nothing left to switch over.
ZUGFeRD is a normal PDF with embedded data. Customers who have not switched yet open it as before — you do not need two versions of your invoices.
What a small business's e-invoice looks like
The difference lies in three fields of the XML — and that is exactly where most mistakes happen:
- Tax category E (exempt), tax rate 0 and tax amount 0. Not Z — that is the zero rate on goods; an invoice coded that way is formally valid but says the wrong thing in substance.
- An exemption reason as text referring to § 19 UStG. This is not a courtesy but a mandatory statement under § 34a UStDV. The standard does not provide a separate code for it.
- Your tax number (Steuernummer) if you do not have a USt-IdNr. (VAT ID) — the rules allow either.
More on the tax categories and why E and Z are constantly mixed up: VAT in the e-invoice.
In E-Rechnung Pro in four steps
With email or a Google account, no payment details.
Name, address, tax number, bank details, logo — once, and then they appear on every invoice.
Choose the small-business exemption as the tax case. The note „Steuerbefreiung gem. § 19 UStG“ ("VAT exemption under § 19 UStG") is prefilled in the form — you can adjust it.
The ZUGFeRD file downloads. With the validator you can see right away whether it meets the rules.
Receiving e-invoices: what you really need
No new program, no platform. An email address to which suppliers send invoices is enough as a receiving channel. The only important thing is that you store the file as it arrived — for ZUGFeRD, that means the whole PDF with the XML inside it, for eight years. See Storing e-invoices.
If you are sent a pure XML file, such as an XRechnung, and you are unsure whether it is correct: the validator checks it against the rules of EN 16931 for free and without sign-up.
To be honest: E-Rechnung Pro has no invoice inbox and does not display the content of an XML file as a readable invoice. It checks files and creates your own — receiving runs through your email inbox.
What it costs
Free and without limits until 31 December 2026. After that, the Free plan includes 10 documents per month and 10 checks per day — enough for most small businesses. On the Free plan and during the beta, the invoice footer carries a small line „Erstellt mit zugferd.randomstar.org“ (on English invoices it reads "Created with zugferd.randomstar.org"). All plans are listed under Pricing.
Frequently asked questions
As a small business, will I have to write e-invoices from 2027 or 2028?
No. The exemption under § 34a UStDV has no end date. It only ends if you exceed the small-business thresholds — then the normal rules apply to you.
Am I allowed to issue e-invoices anyway?
Yes. The exemption is a relief, not a ban. The reference to § 19 UStG must then be in the XML.
Do I have to accept e-invoices from suppliers?
Yes, since 1 January 2025 — like every business in Germany. An email address is enough for that.
Which tax category is right for me?
E (exempt) with an exemption reason that refers to § 19 UStG. Not Z (zero rate) and not "no tax".
I do not have a USt-IdNr. — does that work?
Yes. For exempt invoices, your tax number is enough. You enter it once in the settings.
What happens if I go over €100,000 in the middle of the year?
Then you are subject to standard VAT from the transaction with which you cross the threshold: you charge VAT, and the normal e-invoicing mandate applies to your B2B invoices. Discuss this with your tax adviser in good time.
Can I invoice customers in other EU countries as a small business?
Since 2025 there has been a special notification procedure for this under § 19a UStG, with a separate identification number carrying the suffix "EX", for EU-wide turnover of no more than €100,000. Whether it is worthwhile for you is something to clarify with your tax adviser; the e-invoice itself works the same way across borders.
Is it free?
Without limits until 31 December 2026, then 10 documents per month on the Free plan. We do not ask for payment details.
Your first small-business e-invoice
Create an account, enter your tax number, select "§ 19 UStG" — the ZUGFeRD file with the correct note downloads. Free until 31 December 2026.