E-invoicing: Specific provisions for small businesses (Section 19 of the German Value Added Tax Act (UStG))
As a small business owner, you are permanently excluded from issuing e-invoices – but not from receiving them. This article clearly distinguishes between the two processes and explains what applies to you.
Introduction
If you make use of the small business scheme under Section 19 of the German Value Added Tax Act (UStG), you may be wondering whether the e-invoicing obligation applies to you at all. The answer is twofold, and it is precisely this distinction that often leads to misunderstandings. We’ll break it down for you.
A clarification first, as there is a common misconception here:
Small businesses are not completely exempt from e-invoicing. They are only exempt from issuing e-invoices – when it comes to receiving them, the obligation applies to them too.
This distinction is the central theme of this article: issuing on the one hand, and receiving on the other. Different rules apply to each.
This article explains both aspects, clarifies the permanent exemption regarding issuing e-invoices and outlines what you need to do to receive them.
Issuing: permanently exempt
When it comes to issuing e-invoices, there is a clear relief for small business owners. They are permanently exempt from the obligation to issue e-invoices.
This exemption was introduced by the Annual Tax Act 2024 and is not limited to a transitional period – it therefore remains in force beyond 2028. As a small business owner, you may continue to issue your invoices as ‘other invoices’, such as paper or PDF invoices.
The recipient’s consent is still required for the electronic transmission of your other invoices – for example, as a PDF via email. The exemption applies only to the format; it does not turn a PDF into an e-invoice, nor is it one.
Receiving: Mandatory from 2025
The situation is different when it comes to receiving e-invoices. Here, small business owners are subject to the same obligation as all other businesses.
Since 1 January 2025, small businesses must also be able to accept e-invoices. There is no transition period for this obligation to accept e-invoices. If a supplier or service provider sends you an e-invoice, you must be able to accept it, make it legible and store it properly.
Even if you are not required to issue e-invoices yourself, your suppliers are entitled to send you e-invoices, and you cannot refuse to accept them. An email inbox is the minimum requirement for receiving e-invoices. We will cover how to receive and make e-invoices legible in a separate section. \[Link zu einem Hilfsartikel]
An overview of both processes
To make the distinction clear, here are both sides side by side.
| Direction | Does this apply to small business owners? |
|---|---|
| Issuing e-invoices | No, permanently exempt (other invoices permitted) |
| Receiving e-invoices | Yes, mandatory from 1 January 2025 |
In short: you must be able to read and retain e-invoices, but you do not have to issue them yourself.
Common sources of error
- Assumption of complete exemption: It is assumed that small business owners are entirely exempt. Only the issuing of e-invoices is exempt; receiving them is mandatory.
- Not prepared to receive e-invoices : There is no way to receive e-invoices. Even just an email inbox is sufficient as a minimum, but one must be in place.
- E-invoice rejected: An incoming e-invoice is rejected. It is not possible to refuse to accept it.
- PDF mistaken for an e-invoice: The business’s own PDF invoice is mistaken for an e-invoice. It is a standard invoice; the exemption does not change this.
- Only a printout provided: An incoming e-invoice is printed out and passed on to us. We require the original structured file.
How we work together
As a small business owner, you continue to issue simple invoices and ensure they are received; we take care of the processing.
Your tasks:
- Issue your own invoices as ‘other invoices’ (e-invoices not required)
- Ensure e-invoices are received, at least via an email inbox
- Forward incoming e-invoices to us in their original format
Our tasks:
- Post the documents and classify them for tax purposes
- Provide support with any queries regarding the small business scheme and the receipt of e-invoices
We will agree the exact breakdown with you.
Frequently asked questions
Are small businesses exempt from e-invoicing?
Only partially. They are permanently exempt from issuing e-invoices. However, they have been required to receive e-invoices since 1 January 2025.
As a small business owner, do I have to issue e-invoices?
No, not even from 2028. You may continue to issue your invoices in other formats, such as paper or PDF invoices.
Do I need the customer’s consent for my PDF invoice?
The recipient’s consent is required for the electronic transmission of any other type of invoice – for example, by email as a PDF. The exemption applies only to the format.
What must I do if a supplier sends me an e-invoice?
You must be able to receive it, make it legible and store it. You cannot refuse to accept it. At the very least, an email inbox is sufficient.
How do I forward incoming e-invoices to you?
In the original format via the agreed method, usually DATEV Unternehmen online or an upload address. A printout is not sufficient. \[Link zu einem Hilfsartikel]
Legal notice
This article provides an overview and is not a substitute for individual advice. The small business scheme and the e-invoicing obligation depend on the individual case; the current legal situation applies.
If you have any questions regarding your small business scheme, please contact us directly.
As at: June 2026