In short
- Kleinunternehmer under § 19 UStG never have to issue e-invoices. Paper and PDF invoices stay allowed.
- They must be able to receive e-invoices since 1 January 2025, like every other business established in Germany.
- An ordinary e-mail inbox is enough to receive, and a free official viewer can display the files.
- If you leave the scheme, you must issue e-invoices from that point once the general deadlines apply.
If you run a small business or work as a freelancer in Germany under the small business scheme (Kleinunternehmerregelung, § 19 UStG), the e-invoicing rules affect you less than most. You never have to send e-invoices. You do, however, have to be able to receive them, and that has applied since 1 January 2025.
This short guide is for expats, freelancers and side businesses in Germany who use the scheme and want a clear answer in English. Facts are from the German VAT rules and the Federal Ministry of Finance (BMF), checked on 14 November 2026.
Sending invoices: paper and PDF stay allowed
Under § 34a of the VAT Implementation Ordinance (UStDV), an invoice from a Kleinunternehmer "can always" be sent as an "other invoice" (sonstige Rechnung). In practice that means paper, or a PDF or other electronic format if your customer agrees.
This exemption is not transitional. While the 2027 and 2028 deadlines apply to other German businesses, a Kleinunternehmer can keep sending the same invoices as before, with no end date.
You may still send e-invoices voluntarily, for example if a large customer's accounts department asks for XRechnung or ZUGFeRD. That is a commercial choice, not a legal duty.
Receiving invoices: mandatory since 1 January 2025
The BMF FAQ states it directly: Kleinunternehmer are exempt from issuing e-invoices "but must nevertheless be able to receive e-invoices". The obligation has applied since 1 January 2025, with no transition period.
Receiving is not complicated:
- An e-mail inbox is enough. You do not need a separate mailbox only for e-invoices.
- No platform or network is required. Germany has no central portal and no mandatory Peppol connection.
- You need a way to read the files. An e-invoice is an XML file, or a PDF with XML inside. The free official viewer at e-rechnung.elster.de displays them, and so does our e-invoice validator, which runs in your browser without uploading the file.
Note
A supplier who sends you a proper e-invoice has met its obligation. You cannot insist on a paper copy instead, so make sure the e-mail address you give suppliers is one you actually read.
Example: a freelance translator in Berlin
Anna works as a freelance translator in Berlin and uses the small business scheme. She invoices her agency clients by PDF, which stays allowed. Her web host and her co-working space are German businesses with turnover above €800,000, so from 2027 they will send her XRechnung or ZUGFeRD invoices by e-mail. Anna opens them in a free viewer and files them with her records. Nothing else changes for her.
When the exemption stops
The exemption is tied to the scheme. The BMF says that a Kleinunternehmer who switches to standard taxation is, under the other conditions, obliged to issue e-invoices from that point. Whether you must issue immediately then depends on the general transitional rules:
| Your situation | Must issue e-invoices for supplies from |
|---|---|
| Leave the scheme, 2026 turnover above €800,000 | 1 January 2027 |
| Leave the scheme, 2026 turnover up to €800,000 | 1 January 2028 |
| Stay in the scheme | Never (receiving only) |
Remember the wider scope rule too: the issuing obligation only applies to invoices between two businesses established in Germany. All German dates are also in our deadlines calendar. Invoices to consumers or foreign clients may stay paper or PDF in any case. Our Germany e-invoicing guide has the full picture.
Software for small businesses
You do not need software to receive, but it helps if you want to create e-invoices voluntarily or keep records tidy. Several German tools have free tiers: Zervant has a €0 plan with up to 5 invoices a month including XRechnung, and Papierkram has a permanent free package for receiving e-invoices and creating ZUGFeRD (as of Nov 2026). See the free e-invoicing options for more, and check current limits with the vendor.
This page is general information, not tax advice. If you are close to the scheme's limits or unsure whether you still qualify, ask a Steuerberater.
Questions people ask
Do Kleinunternehmer have to send e-invoices?
No. Under § 34a UStDV, a Kleinunternehmer may always issue an 'other invoice', meaning paper or, with the customer's consent, a PDF. This exemption has no end date.
Do Kleinunternehmer have to receive e-invoices?
Yes. Since 1 January 2025 every business established in Germany, including Kleinunternehmer, must be able to receive e-invoices. An e-mail address is enough.
Can a customer insist on an e-invoice from a Kleinunternehmer?
Not under VAT law. A customer may ask for one as part of the contract, and sending one voluntarily is allowed, but the law does not require it.
What happens if I lose Kleinunternehmer status?
If you switch to standard VAT taxation, you are obliged to issue e-invoices from that point, subject to the general transitional dates of 2027 and 2028.
Official sources
- § 34a UStDV: Rechnungen von Kleinunternehmern gesetze-im-internet.de
- BMF: Fragen und Antworten zur Einführung der obligatorischen E-Rechnung bundesfinanzministerium.de
- BMF letter of 15 October 2025 on the mandatory e-invoice bundesfinanzministerium.de
- § 27 UStG: Allgemeine Übergangsvorschriften (Abs. 38) gesetze-im-internet.de
General information, not tax or legal advice. Check edge cases with a tax adviser.