Do Kleinunternehmer have to issue e-invoices?
No, Kleinunternehmer (small businesses under § 19 UStG) do not have to issue e-invoices. But since 1 January 2025 they must be able to receive them, like every business in Germany. An email inbox is enough for this.
Kleinunternehmer (small businesses under § 19 UStG, the German VAT Act) are exempt from the obligation to issue e-invoices. They are not exempt from receiving them. The Federal Ministry of Finance (BMF) says so explicitly.
What do Kleinunternehmer need to do?
Since 1 January 2025, all businesses in Germany must be able to receive e-invoices, including Kleinunternehmer. There are no exceptions to this.
This is simpler than it sounds: an email inbox is enough. If you receive an XRechnung, though, you will only see code in it. Open the file in a viewer instead, for example here, directly in your browser:
Do Kleinunternehmer have to issue e-invoices?
No. Supplies by Kleinunternehmer do not need an e-invoice; an “other invoice” (sonstige Rechnung), for example on paper or as a PDF, is possible. If you switch to standard VAT taxation, you must also issue e-invoices yourself from that point on, once the transition periods have ended.
How do I keep the e-invoices I receive?
For VAT purposes, you must keep every incoming and outgoing invoice for 8 years. For an e-invoice, you must keep at least the structured part, meaning the XML file, unaltered and in its original form. So save the original file, not just a printout.
Read the full guide: When do e-invoices become mandatory in Germany?
Frequently asked questions
As a Kleinunternehmer, may I still issue e-invoices?
What happens if I switch to standard VAT taxation?
Do I need special software to receive e-invoices?
Do freelancers and landlords also count as businesses?
Related guides
When do e-invoices become mandatory in Germany?
An overview of the e-invoicing rules in Germany: receiving since 1 January 2025, issuing in stages up to 1 January 2028, the exceptions and what you should do now.
XRechnung or ZUGFeRD: what is the difference?
Both formats count as e-invoices. The difference: ZUGFeRD is a PDF with embedded data, XRechnung is data only. Here is how to read both.
Sources
- Questions and answers on the introduction of mandatory e-invoicing, questions 3, 4, 8 and 12 (BMF, as of March 2026) (in German)
- E-invoice viewer of the tax authorities (ELSTER) (in German)
This guide is general information, checked against the official sources above. It is not legal or tax advice; for your own situation, ask your accountant or software provider.