E-Invoice for Small Businesses in Germany: Required or Not?

If you are a Kleinunternehmer (small business owner under § 19 UStG), you do not have to issue e-invoices: paper always works, and a PDF works with your customer's consent. You do have to be able to receive them since January 1, 2025, and an e-mail inbox is enough. If you switch to regular VAT, the general rules apply.

Last updated: October 27, 2026

In brief

Receiving: Required since January 1, 2025, also for small businesses. An e-mail inbox is enough.
Issuing: As a small business you may always use an other invoice (paper or PDF).
Switching: Once you move to regular VAT, the general e-invoice deadlines apply to you.

Do I have to issue e-invoices as a small business?

No. The duty came with the Wachstumschancengesetz and applies to invoices between domestic businesses (§ 14 para. 2 sentence 2 no. 1 UStG). Small businesses have an express exception: an invoice under § 34a UStDV can always be sent as an "other invoice" (sonstige Rechnung). The German Federal Ministry of Finance (BMF) therefore lists services by small businesses among the cases where no e-invoice is needed.

What is an "other invoice"? Paper, or another electronic format such as a PDF by e-mail. You may send the PDF if your customer agrees (BMF letter of October 15, 2025, margin no. 22). The consent needs no special form: if your customer accepts the PDF without objection, that counts as implied consent (section 14.1 para. 7 UStAE).

If you want to send an e-invoice anyway, you may. Under the other conditions it is always possible without the recipient's consent (BMF letter, margin no. 22).

Do I have to receive e-invoices as a small business?

Yes. Since January 1, 2025, domestic businesses must be able to receive an e-invoice. The BMF provides no exceptions and names small businesses explicitly. In practice your e-mail inbox is enough, since e-mail is a permitted way to transmit an e-invoice.

Then the real work starts: an XRechnung is a plain XML file and needs a viewer, which the tax administration offers at e-rechnung.elster.de. How to read and check incoming invoices is covered in Receive and read e-invoices. You must keep incoming and outgoing invoices for eight years, and for an e-invoice at least the structured part, unaltered (§ 14b para. 1 UStG, BMF FAQ question 13).

When does this change for me?

As soon as you stop being a small business. That happens when you opt out of the small business scheme or exceed the turnover limit: 25,000 euros in the previous year or 100,000 euros in the current year (§ 19 para. 1 UStG); in the year you start your business, the limit for the current year is already 25,000 euros (Finanzamt Hessen). If you exceed the limit during the current year, the scheme ends immediately (Finanzamt Hessen). From that point, the BMF says you must also issue e-invoices under the other conditions. More on the switch: Switching from small business to regular VAT.

The transition rule in § 27 para. 38 UStG then applies. For invoices to domestic businesses:

Your case	What applies to the invoice
Small business	other invoice always allowed, e-invoice optional
Regular VAT, supply made in 2025 or 2026	other invoice allowed (PDF with consent) if you transmit it by 31 December 2026
Regular VAT, supply made in 2027, previous-year total turnover at most 800,000 euros	other invoice allowed (PDF with consent) if you transmit it by 31 December 2027
Regular VAT, supply in 2027 with more than 800,000 euros previous-year turnover, or from 2028	e-invoice, except for example small amounts up to 250 euros gross (§ 33 UStDV)

What counts is when the supply was made, not the invoice date; on top of that comes the cut-off date for transmission. A paper or PDF invoice for a delivery made in December 2026 that you send only in January 2027 is no longer covered by § 27 para. 38 no. 1 UStG. The full overview for sellers is in E-invoice obligation in Germany 2027.

What belongs on a small business invoice?

An invoice under § 34a UStDV needs at least these details:

full name and address of you and your customer,
your tax number, VAT ID or small business identification number,
the date of issue,
quantity and type of the goods, or scope and type of the service,
the fee as one total with a note that the small business exemption applies (§ 19 UStG).

You do not show VAT separately (Finanzamt Hessen). How the note can read and what applies to small amounts is in Small business invoice in Germany. With an e-invoice, all mandatory details must be in the structured part, not just in an attached PDF (BMF FAQ question 7a).

Which format fits your invoice?

Option	When it fits
Paper	always allowed
PDF by e-mail	with the customer's consent, also implied
ZUGFeRD	readable PDF with embedded data; your customer can open it like a PDF
XRechnung	plain XML file; sensible if your customer asks for it, for example a public authority

The BMF recognizes in particular the XRechnung, and ZUGFeRD from version 2.0.1 except for the ZUGFeRD profiles MINIMUM and BASIC-WL. A plain PDF is not an e-invoice. The difference between the two formats is explained in XRechnung or ZUGFeRD.

Common mistakes

Calling a plain PDF an e-invoice. It is an other invoice, not an e-invoice, and as a PDF it needs your customer's consent.
Assuming small businesses need not receive either. Receiving is required without exception.
Missing the switch to regular VAT. From then on the e-invoice deadlines apply to you.
Showing VAT in the e-invoice. The same rule holds: no separate VAT, but the note on § 19 UStG.

How VAT GPT helps

On the Income page, open "Generate Invoice" in the "Tips" card.
Under "Format", choose ZUGFeRD (PDF) or XRechnung (XML). If the small business scheme is saved in your profile, the editor adds the § 19 UStG note to the invoice for services in Germany.
Download the file. VAT GPT reads incoming ZUGFeRD PDFs and XRechnungen when you upload them.

There are Free, Go (30 days free with all Pro features) and Pro (€49 per month or €444 per year, including VAT). Try for free now

Frequently asked questions

Do I have to issue e-invoices in 2027 as a small business? No, as long as you are a small business: an invoice under § 34a UStDV can always be sent as an other invoice.

Do I have to be able to receive e-invoices? Yes, since January 1, 2025. An e-mail inbox is enough.

May I send an e-invoice voluntarily? Yes, under the other conditions without your customer's consent.

Is a PDF enough? As an other invoice yes, if your customer agrees. As an e-invoice it does not count.

What changes if I exceed 100,000 euros (25,000 euros in the year I start)? The small business scheme ends immediately and the general rules of regular VAT apply, including the form of the invoice.