Kleinunternehmer VAT Annual Return 2026: Required or Not?

Short and honest: Since the 2024 tax year, Kleinunternehmer (small-business owners under §19 UStG) in Germany no longer have to file an annual VAT return. The Wachstumschancengesetz (Growth Opportunities Act) rewrote §19 UStG to drop the obligation – a genuine win for solo founders and freelancers with low revenue. The same exemption applies for 2025 and 2026.

But "generally" does not mean "always". Five special situations can still trigger a VAT return obligation – for example, if you book Facebook ads from Ireland, accidentally charge VAT on an invoice, or buy goods from EU suppliers. Miss one of these, and you risk back-payments plus late-filing penalties.

This article covers: who is exempt, who must still file, what happens to the quarterly VAT pre-return (UStVA), and which tax filings remain mandatory for Kleinunternehmer in 2026.

The essentials at a glance

• The rule: Since the 2024 tax year, Kleinunternehmer no longer file an annual VAT return – and never had the quarterly pre-return (UStVA). Nothing to apply for; the exemption applies automatically.
• New from 2025: The Kleinunternehmer scheme is now a genuine tax exemption (not just non-collection), and the thresholds rose to €25,000 (prior year) and €100,000 (current year).
• Five exceptions bring the obligation back: accidental VAT charge (§14c), reverse-charge on foreign services (§13b), EU purchases above €12,500 (§1a), imports from non-EU countries, and switching to standard taxation.
• Still mandatory: income tax return, Anlage EÜR, trade tax where applicable, and the recapitulative statement (Zusammenfassende Meldung).
• Since 2025 even Kleinunternehmer must be able to receive e-invoices – issuing them stays optional for now.

The basic rule from 2024: No more annual VAT return

If you use the Kleinunternehmer scheme under §19 UStG, you are exempt from filing the annual VAT return starting with the 2024 tax year. Concretely:

• No VAT return required – neither electronically via ELSTER nor on paper.
• No quarterly pre-returns (UStVA): Kleinunternehmer never had a UStVA obligation, and a zero VAT return (Nullmeldung) is not required either.
• The exemption applies automatically. No application, no form, no notification to the tax office. As long as you meet the thresholds, the scheme applies.

Before 2024 it was different: even Kleinunternehmer had to file a "zero return" – paperwork without any fiscal benefit. That obligation is gone.

New since 1 January 2025: The legislator reworked §19 UStG once more. The former "non-collection" of VAT has become a genuine tax exemption – your turnover is now tax-free, not merely untaxed. At the same time, the revenue thresholds went up:

One important detail about the new €100,000 limit: it bites immediately. If you exceed it during the year, you switch to standard taxation from the exact transaction that breaches the limit – not from the following year as with the €25,000 limit.

The five exceptions: When you must still file

There are five situations where the exemption does not apply. In each of these, you actually owe VAT – and must declare it. Here is the overview, then each exception in detail:

1. Accidentally charging VAT (§14c UStG)

If you accidentally charge VAT on an invoice (e.g. "19% VAT: €19"), you owe that VAT to the tax office – even as a Kleinunternehmer. This is the wrongful tax statement trap under §14c UStG. Consequence: a VAT return is required for that period.

How to avoid it: Every invoice must carry the line "No VAT charged pursuant to §19 UStG". Automated e-invoicing tools prevent this slip.

2. Reverse-charge on foreign services (§13b UStG)

Booking online ads from Google (Ireland), Facebook/Meta (Ireland), Microsoft Ads (Ireland) or software subscriptions from US vendors? You become the tax debtor as the recipient – even as a Kleinunternehmer. This is the reverse-charge mechanism under §13b UStG.

You must calculate fictitious German VAT (usually 19%) on the invoice net, pay it to the tax office, and declare it in a VAT return. Input VAT deduction is denied – which makes online ads more expensive for Kleinunternehmer than they look at first glance. Example: on €500 of Meta ads a month, you owe €95 in VAT you cannot reclaim.

3. Intra-community acquisitions (§1a UStG)

If you buy goods from EU suppliers (e.g. hardware on Amazon.it or from a Polish wholesaler), once you exceed the acquisition threshold of €12,500 net per year, you must declare and pay German VAT on the net amount.

Even voluntarily using your VAT ID number toward the supplier triggers tax liability immediately – regardless of the amount.

4. Import VAT from non-EU countries

When you import goods from the US, China, the UK or other third countries, import VAT (EUSt) applies. You pay it at customs, independent of your Kleinunternehmer status. A separate VAT return is usually not required, but you must document the transaction in your bookkeeping.

5. Switching to standard taxation mid-year

Did you exceed the €25,000 threshold in the prior year (2025) – or voluntarily opt out of the Kleinunternehmer scheme? Then from 1 January 2026 you are subject to standard VAT and must file full UStVAs plus an annual return. And since 2025 there is a second path: if you breach the €100,000 limit mid-year, you flip into standard taxation immediately – from the transaction that crosses the line. See our guide on switching from Kleinunternehmer to standard VAT.

What stays mandatory for Kleinunternehmer in 2026?

The VAT return goes away – but not everything. You still have to file these:

For profit determination, the Anlage EÜR (income-surplus calculation) is enough; the recapitulative statement only concerns you if you yourself supply goods or services to other EU countries.

Important: The tax office may still individually request a VAT return (§149 (1) sentence 2 AO). If such a request arrives in your mailbox, you must comply.

New since 2025: Being able to receive e-invoices

Even though you may still issue paper or PDF invoices as a Kleinunternehmer, since 1 January 2025 every domestic business must be able to receive structured e-invoices – Kleinunternehmer included, no exceptions. An email inbox is technically enough to receive them, but the file must also be stored in a GoBD-compliant way and archived for ten years. Details in our guide to e-invoicing for Kleinunternehmer. The obligation to issue e-invoices yourself only applies to Kleinunternehmer from 2028.

The starter book for your self-employment

Free e-book: registration, accounting, your first invoice, and taxes, plus a tax calendar, deductions cheat sheet, and invoice template.

Email *

Company website

I want to receive the starter book and agree that Norman may send me related emails with tips and product info. Details in the privacy policy. Unsubscribe anytime. *

Get the free book

2026 deadlines – in case you do have to file

If one of the exceptions applies, the standard VAT deadlines in Germany apply:

• Without a tax advisor: 31 July 2026 for the 2025 tax year.
• With a tax advisor: 28 February 2027 for the 2025 tax year.

A filing extension (Dauerfristverlängerung) only helps with the UStVA, not the annual return. For what that return then looks like, see our guide to the annual VAT return.

How Norman makes this easier

Norman is built for Kleinunternehmer and Selbstständige in Germany. Specifically:

• Free invoicing with the automatic §19 disclaimer – no accidental VAT charges.
• Automatic EÜR built from your bank data and receipts.
• Reverse-charge detection: When you book Google or Meta ads, Norman flags the transaction and reminds you that a VAT filing is required.
• Receive and GoBD-archive e-invoices – so the 2025 receiving obligation is covered.
• Income tax filing directly in the tool – including Anlage S/G and EÜR.

More on Norman for Selbstständige is on the taxes for self-employed page.

Frequently asked questions (FAQ)

Do Kleinunternehmer have to file a VAT return?

Generally no. Since the 2024 tax year, Kleinunternehmer under §19 UStG are exempt from the annual VAT return, and the exemption applies automatically. It only fails to apply when one of the five exceptions is met – such as reverse-charge on foreign ads or an accidental VAT charge.

Do I have to file a VAT pre-return (UStVA) as a Kleinunternehmer?

No. Kleinunternehmer never had a UStVA obligation, and that has not changed. A zero return is not needed either. Only once you switch to standard taxation does the UStVA come into play.

What is the difference between the VAT return and the income tax return?

The VAT return concerns the VAT on your turnover – which drops away for Kleinunternehmer. The income tax return concerns your profit and stays mandatory for every self-employed person, including Anlage EÜR. They are separate filings; being exempt from one changes nothing about the other.

Do I have to be able to receive e-invoices as a Kleinunternehmer?

Yes. Since 1 January 2025, every domestic business must be able to receive e-invoices and archive them in a GoBD-compliant way – Kleinunternehmer included. You only have to issue them yourself from 2028; until then paper and PDF remain allowed.

What happens if I book Google or Facebook ads as a Kleinunternehmer?

Then the reverse-charge mechanism under §13b UStG applies: you become the tax debtor, must declare and pay German VAT (usually 19%) on the invoice amount yourself – with no input VAT deduction. In that case you are required to file a VAT return even though you would otherwise be exempt.

Bottom line

Since 2024, Kleinunternehmer are generally exempt from the annual VAT return – the biggest tax-bureaucracy relief for solo founders in years. But beware: §14c, reverse-charge, EU purchases, and switching to standard taxation can bring the obligation back instantly. If you book online ads or buy internationally, watch carefully – or the supposed bureaucratic relief turns into an expensive back-payment.