E-invoicing: Who is affected?
The e-invoicing requirement does not apply to everyone to the same extent. This article explains who is affected, which invoices are exempt, and why the receipt and issuance of invoices should be considered separately.
Introduction
Whether and how the e-invoicing requirement affects you depends on who you do business with and whether you receive, issue or both. The requirement applies to transactions between domestic businesses (B2B). We’ll help you work out what applies in your situation.
A few clarifications first, as there are often misunderstandings here: as a small business owner or a tax-exempt business owner (e.g. doctors), you are not completely exempt. Whilst you do not have to issue e-invoices, you must be able to receive them.
Similarly, the requirement does not apply only to large businesses. It is linked to business status, not to size.
And it applies to domestic transactions – business with private customers is excluded.
This article first covers who is generally affected, then the exceptions, and finally the special case of small business owners.
Who is generally affected
Domestic businesses that provide services to other domestic businesses are affected. This is known as B2B business – business between companies.
‘Domestic’ means that both parties are based in Germany. The German e-invoicing requirement applies to these domestic business relationships. The German rules do not apply to invoices sent to customers in other EU countries; in such cases, the recipient country’s own regulations may apply.
The legal form is irrelevant. Sole traders, partnerships, companies, self-employed professionals and associations operating in the commercial sector are all equally covered as soon as they engage in business-to-business transactions.
Receipt and issuance: the impact differs
The obligation is divided into two aspects, which do not affect everyone in the same way.
The obligation to receive e-invoices (i.e. to be technically capable of receiving them) has applied to every domestic business since 2025 – with no transition period and no exceptions based on size. Anyone who purchases goods or services from other businesses must be able to accept an e-invoice.
The obligation to issue e-invoices applies only to those who themselves issue VAT-liable invoices to other domestic businesses, and it will become mandatory gradually over transition periods.
As small business owners and other tax-exempt traders (such as doctors) do not invoice for services subject to VAT, they are not required to issue e-invoices. The same applies to businesses insofar as they invoice consumers (B2C). Nevertheless, these businesses must also be able to receive e-invoices in their own inbox, as they are, in turn, regarded as B2B customers from their suppliers’ perspective.
In addition, there are exceptions that permanently exempt certain invoices from the obligation to issue them. We will deal with the deadlines separately.
Even those exempt from the obligation to issue e-invoices – such as small business owners – remain obliged to receive them. The exemption always applies to only one of the two directions.
Who is exempt from the obligation to issue e-invoices
Certain invoices will still not be required to be issued as e-invoices in future. These exemptions apply regardless of the transition period.
Invoices to private individuals (B2C)
Invoices to private customers are not covered by the e-invoice requirement. You may continue to use paper or PDF formats for these. The key criterion is that the recipient is not receiving the service for their business.
Small-value invoices up to 250 euros
Invoices up to a total gross amount of 250 euros are exempt (Section 33 UStDV). This includes many everyday receipts, such as a petrol receipt or a small purchase. The simplified details continue to apply to these.
Travel tickets
Travel tickets for passenger transport are also exempt. A train or bus ticket does not need to be issued as an e-invoice.
Certain tax-exempt transactions
Transactions that are tax-exempt under Section 4 Nos. 8 to 29 of the German Value Added Tax Act (UStG) do not need to be issued as e-invoices. These include, for example, certain financial and insurance services, medical treatment or tax-exempt lettings.
An overview of the exemptions
| Exemption | What this covers | Consequence |
|---|---|---|
| B2C | Invoices to private customers | No obligation to issue e-invoices |
| Small amounts | Invoices up to €250 gross | Paper/PDF still permitted |
| Travel tickets | Tickets for passenger transport | No obligation to issue e-invoices |
| Tax-exempt transactions | Section 4 Nos. 8–29 of the German Value Added Tax Act (UStG) | No obligation to issue |
These exemptions relate to the issuing of invoices. Conversely, if you receive an e-invoice for a small amount, you may of course accept and process it – the recipient is not affected by this.
Special case: small businesses (Section 19 of the German Value Added Tax Act (UStG))
Small businesses under Section 19 of the German Value Added Tax Act (UStG) are the most common source of misunderstandings, as the rules apply to them differently in both directions.
When it comes to issuing e-invoices, small businesses are permanently exempt. Even after 2028, they will not be required to issue e-invoices and may continue to use paper or PDF formats. They may issue e-invoices on a voluntary basis, which some business customers already prefer.
When it comes to receiving e-invoices, small business owners are subject to the same obligations as everyone else. From 2025, they too must be able to accept and process e-invoices. The statement ‘As a small business owner, this doesn’t affect me’ therefore only applies to issuing e-invoices, not to receiving them. We explore the situation for small business owners in more detail in a separate article:
What this means for you
In practice, most cases can be categorised into one of three situations.
If you only receive services and issue invoices yourself only rarely or only to private customers, you are primarily affected by the requirement to receive e-invoices. In that case, it is sufficient to be able to process incoming e-invoices.
If you regularly issue invoices to other businesses, the issuing of invoices also applies to you – subject to the relevant transition period. In this case, it is worth taking a look at your invoicing software.
If you mainly have exempt turnover – for example, as a healthcare professional or a landlord with tax-exempt lettings – you are not obliged to issue e-invoices in this area; however, the obligation to receive them still applies. We will examine such situations on a case-by-case basis.
Common sources of error
- Overlooking the obligation to receive e-invoices: Those exempt from issuing e-invoices may assume they are not affected at all. However, the obligation to receive e-invoices applies regardless, meaning incoming e-invoices may remain unprocessed.
- B2C incorrectly classified: A business customer is treated as a private customer. The obligation applies to services provided to businesses, which leads to complaints at a later stage.
- Small-amount threshold exceeded: An invoice just over 250 euros is treated as a small amount. Above this threshold, the standard rules apply, meaning the format is incorrect.
- Foreign invoice confused with domestic one: The German requirement is applied to EU customers, or conversely, it is overlooked that separate rules may apply there. The nature of the transaction determines which law applies.
- Tax-exempt supply assumed across the board: A business considers all its supplies to be tax-exempt, even though a taxable portion is included. The requirement may apply to the taxable portion.
Frequently asked questions
Am I affected as a small business owner?
Not when issuing invoices – small business owners are permanently exempt. When receiving invoices, yes – from 2025, just like any other business. So you are not completely exempt.
Does the requirement also apply to invoices issued to private customers?
No. Invoices to private individuals are not affected. In such cases, you may continue to use paper or PDF.
Does an invoice for over 100 euros have to be an e-invoice?
Invoices up to 250 euros gross are exempt as small-value invoices. An invoice for over 100 euros issued to a business therefore falls under the exemption, provided it does not exceed this limit.
We only do business with customers abroad – does this apply to us?
The German e-invoicing requirement applies to domestic transactions between German businesses. The German rules do not apply to overseas customers; however, the respective country may have its own regulations.
Does the requirement also apply to associations?
Where an association carries out commercial activities, the same rules apply as for other businesses. The requirement does not apply to purely non-profit activities. We cover this in a separate article for associations. \[Link zu einem Hilfsartikel]
I only have tax-exempt transactions – do I have to issue e-invoices?
There is no obligation to issue e-invoices for transactions that are tax-exempt under Section 4 Nos. 8 to 29 of the German Value Added Tax Act (UStG). If you also provide taxable services, the obligation may apply to these. In any case, you must receive e-invoices.
Does my legal form matter?
No. The obligation is linked to your status as a business operator, not to your legal form. Sole traders, companies and self-employed professionals are treated equally.
Legal notice
This article provides an overview and is not a substitute for individual advice. The legal situation and its interpretation may change; the current status at any given time is decisive. Whether and to what extent the obligation applies to you depends on your activities and your business relationships.
If you have any questions about how this affects you, please contact us directly.
As at: June 2026