E-Invoicing for Kleinunternehmer 2026: Rules & Exemptions

Since 1 January 2025, Germany has had a mandatory e-invoicing rule for B2B transactions. Many small businesses (Kleinunternehmer) have been wondering ever since: does this even affect me – and do I now have to buy expensive software just to send invoices in a structured format?

The good news first: small businesses under § 19 UStG are exempt from the obligation to issue e-invoices. You can keep writing paper or PDF invoices. The lesser-known news: you still have to be able to receive e-invoices – and that obligation already applies today.

In this article you will learn which rules actually apply to small businesses, what the exemption under § 34a UStDV means exactly, which deadlines matter, and how to set yourself up correctly with minimal effort.

The essentials at a glance

• Issuing: small businesses are permanently exempt from the e-invoicing obligation under § 34a UStDV. You may keep writing paper or PDF invoices.
• Receiving: since 1 January 2025, every business – including small businesses – must be able to receive e-invoices and archive them GoBD-compliant.
• Technology: an email inbox is enough to receive them. To read and archive them audit-proof, you need a suitable solution.
• Retention: since 2025, e-invoices must be kept unchanged for 8 years (previously 10 years).
• Thresholds: the exemption only applies while you stay below €25,000 (prior year) and €100,000 (current year).

What is an e-invoice anyway?

An e-invoice is not simply a PDF file sent by email. It is an invoice in a structured electronic format that can be read by machines and complies with the EU norm EN 16931. In Germany this mainly means two formats:

• XRechnung – a pure XML format, common above all in the public-sector (B2G) space
• ZUGFeRD – a hybrid format combining a PDF with embedded XML, readable by humans and machines alike

A classic PDF invoice, by contrast, has only counted as an "other invoice" (sonstige Rechnung) since 2025. It is still permitted, but it does not meet the technical requirements of an e-invoice. For more on which format makes sense when, read our comparison of XRechnung vs. ZUGFeRD.

Do small businesses have to issue e-invoices?

No. With the Annual Tax Act 2024 (Jahressteuergesetz 2024), the legislator explicitly exempted small businesses from the obligation to issue them. This is anchored in § 34a UStDV: Kleinunternehmer may continue to issue their invoices as "other invoices" – that is, on paper or as a PDF. Unlike the general transition periods, this exemption is not time-limited: it applies for as long as you remain a small business.

Important: this only applies as long as you actually use the small-business scheme. Since 2025 the thresholds are €25,000 turnover in the prior year and €100,000 in the current year. Exceed them and switch to standard taxation, and the normal e-invoicing obligation applies – then you must issue e-invoices like any other business.

But: you must be able to receive e-invoices – right now

This is the most common misunderstanding. The exemption only covers issuing, not receiving. Since 1 January 2025, every domestic business – including every small business – must be able to receive e-invoices and archive them in a GoBD-compliant way.

The good news: technically an email inbox is enough. Your business partners can simply send you the XRechnung or ZUGFeRD file by email. But you do need a way to make the structured data readable and store it in an audit-proof manner. Our detailed guide receiving e-invoices shows how that works step by step. An AI-powered bookkeeping tool reads e-invoices automatically and files them correctly.

Issuing or receiving? Your obligations at a glance

The two directions are often confused. This table separates them cleanly:

So for you as a small business only one real obligation remains: receiving. Everything else is voluntary.

The deadlines at a glance

Staggered transition periods apply to issuing – but they are secondary for you as a small business, since you are exempt anyway:

Note: none of these issuing deadlines forces you to do anything as a small business. The only deadline that affects you has already passed – the receiving obligation since the start of 2025.

When issuing e-invoices voluntarily makes sense

As a small business you may issue e-invoices voluntarily – and sometimes that is the smart move:

• Larger corporate clients increasingly demand e-invoices and process PDFs reluctantly.
• Public-sector clients in the B2G area often accept XRechnung only.
• You avoid the media break if your bookkeeping is digital anyway.
• If you can see yourself growing past the small-business threshold, you save yourself the switch later.

If you already work digitally, you can create invoices for free directly as e-invoices – at no extra effort. Norman supports both XRechnung and ZUGFeRD. Read more on our e-invoicing page.

How to store e-invoices correctly

Even if you don't issue e-invoices yourself: the e-invoices you receive are subject to the retention obligation. And this is where something changed in 2025.

The Fourth Bureaucracy Relief Act (BEG IV) shortened the retention period for invoices and accounting records from 10 to 8 years (§ 147 (3) AO, § 257 (4) HGB). The new period applies to all documents whose previous 10-year period had not yet expired at the end of 2024 – in practice, from 2025 onward.

Two points are decisive:

• The original counts. In a ZUGFeRD invoice, the embedded XML dataset is the tax-relevant original, not the printout. It must be kept unchanged.
• The inbox is not enough. Leaving an e-invoice only in your email inbox or on a hard drive is not GoBD-compliant. You need audit-proof storage where documents cannot be altered afterwards.

That is exactly what bookkeeping software handles for you: it stores the original file, logs every change, and keeps everything audit-ready for the tax office.

Special case: small-value invoices

Invoices up to €250 gross (Kleinbetragsrechnungen) are generally exempt from the e-invoicing obligation – this applies to all businesses, not just small ones. Travel tickets and certain VAT-exempt transactions are also outside the scope. For details, see the article on the small-value invoice.

Common mistakes by small businesses

• Ignoring receiving: "I don't issue e-invoices, so this doesn't affect me" – wrong. The receiving obligation still applies.
• Treating a PDF as an e-invoice: An ordinary PDF does not automatically meet audit-proof receiving and archiving requirements.
• Just printing and filing: The printout of an e-invoice does not replace the digital original.
• Forgetting consent: Anyone still sending PDF/paper needs the recipient's consent.
• Overlooking the thresholds: Breach the small-business limits and you lose the exemption – see E-invoicing obligation 2026.

Frequently asked questions about e-invoicing for small businesses

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

No. Under § 34a UStDV you are permanently exempt from the obligation to issue e-invoices. You may keep writing paper or PDF invoices – as long as you use the small-business scheme.

Do I have to be able to receive e-invoices?

Yes. Since 1 January 2025, every domestic business must be able to receive and store e-invoices – including small businesses. Technically an email inbox is enough for this.

Is a normal email inbox enough to receive them?

For the mere receipt, yes. To read the structured data and store it audit-proof and GoBD-compliant, you also need suitable software – the inbox alone does not satisfy the retention obligation.

How long do I have to keep e-invoices?

Since 2025 the period is 8 years (previously 10 years), counted from the end of the year in which the invoice was issued. The original file must remain unchanged.

May I issue e-invoices voluntarily as a small business?

Yes. It can make sense if corporate clients demand it, if you supply public-sector clients, or if you can see yourself growing past the small-business threshold.

What happens if I exceed the small-business threshold?

Then you become standard-taxed and lose the exemption under § 34a UStDV. From the switch onward the normal e-invoicing obligation applies, and you must issue e-invoices.

Conclusion: little obligation, a bit of preparation

As a small business you have it comparatively easy: you do not have to issue e-invoices and may keep using PDF or paper. The only obligation is that you can receive and properly store e-invoices – and that has applied since the start of 2025.

Norman takes exactly this part off your plate: e-invoices are read automatically, archived in a GoBD-compliant way and – if you want – created in the right format too. So you are prepared without ever wrestling with XML standards.