Kleinunternehmer invoices under § 19 UStG: no VAT, the § 19 reference, E-Rechnung

A Kleinunternehmer under § 19 UStG sells without Umsatzsteuer, and that single fact changes the invoice in several places at once: no tax rate, no tax amount, a sentence on the document explaining why, a shorter list of particulars than an ordinary German invoice, and no Vorsteuer coming back on anything bought. Two further things have been true since 1 January 2025. The turnover limits were rewritten by the Jahressteuergesetz 2024, and the German e-invoice mandate arrived with them. This page sets out what the statute now says, what the invoice must carry, what happens the moment a limit is passed, and exactly where the E-Rechnung duty does and does not bite a Kleinunternehmer. KRONENWERK is a software company and not a tax adviser; the figures below are the statute's, but your own case belongs with your Steuerberater.

What § 19 UStG actually does

Read the first sentence of § 19 Abs. 1 UStG closely, because the wording changed and the change has consequences. A turnover made by a business established in Germany "ist steuerfrei" — is tax-exempt — where the Gesamtumsatz did not exceed 25 000 euro in the preceding calendar year and does not exceed 100 000 euro in the current one. Before 2025 the statute said the tax "wird nicht erhoben", was not levied. The shift from "not levied" to "exempt" is not cosmetic: exemption is the category that § 15 Abs. 2 Satz 1 Nr. 1 UStG uses to shut off the Vorsteuerabzug, and it is the category the EU small-business scheme uses across the Union.

The same sentence of § 19 Abs. 1 then switches off a list of ordinary obligations. The rules on exempt intra-Community supplies, the option to tax under § 9, the duty to put USt-IdNr. on an invoice under § 14a, and — the one most businesses notice — the declaration duties of § 18 Abs. 1 bis 4 UStG do not apply. That is the statutory basis for the familiar statement that a Kleinunternehmer files no Umsatzsteuervoranmeldung. Two things are expressly left standing: the Finanzamt can still demand a return under § 149 Abs. 1 Satz 2 AO, and § 18 Abs. 4a keeps its own cases alive, for instance where the business owes tax as the recipient of a reverse-charge supply. The exemption is also not automatic in the sense of being irreversible: under § 19 Abs. 3 a business may declare a waiver to the Finanzamt, which then binds it for at least five calendar years.

The two turnover limits since 1 January 2025

Both tests must be satisfied at the same time. The Gesamtumsatz is defined in § 19 Abs. 2 UStG: the sum of taxable turnovers computed on payments actually received, less certain exempt turnovers, and with sales of fixed assets left out of the calculation. Because the turnover is itself exempt from 2025, the figures are net amounts.

The moment a limit is passed

The 100 000 euro test is the one that catches people out, and it behaves differently from the 50 000 euro figure it replaced. The old figure was a prediction made at the start of the year; if the prediction was honest, going over it during the year did no harm. The new one is not a prediction. The statute reads "im laufenden Kalenderjahr 100 000 Euro nicht überschreitet" in the present tense, and the effect is immediate: the very turnover that carries the total past 100 000 euro is already outside the exemption and falls under ordinary taxation, while everything invoiced before it stays exempt. There is no grace period and no end-of-year reckoning. The same immediate switch applies to the 25 000 euro figure in a first year of trading.

Practically, this makes running turnover a number a Kleinunternehmer has to watch rather than compute in March. It also means a single large job can split a year in two: invoices before the threshold carry the § 19 reference and no tax, invoices after it carry a rate and a tax amount and need the full § 14 UStG particulars. Exceeding the 25 000 euro figure in a year has a different shape — it does no harm to that year, but it ends the exemption for the following one. Where the boundary falls in your year is a question for your Steuerberater, not for software.

What a Kleinunternehmer invoice must show

The particulars are not in § 14 Abs. 4 UStG but in § 34a UStDV, a simplification made under § 14 Abs. 6 Nr. 3 UStG and headed "Rechnungen von Kleinunternehmern". An invoice for turnover exempt under § 19 Abs. 1 must contain at least six things: the full name and full address of the supplier and of the recipient; the Steuernummer issued by the Finanzamt, or the USt-IdNr. or Kleinunternehmer-Identifikationsnummer issued by the Bundeszentralamt für Steuern; the date of issue; the quantity and commercial description of the goods or the extent and nature of the service; the consideration as a single sum together with a reference to the fact that the small-business exemption of § 19 UStG applies; and, where the recipient or a third party issues the document, the word "Gutschrift".

Two readings of that list are worth having. First, what the list does not contain: it has no separate tax rate and no tax amount, which is the whole point, and it does not require the sequential invoice number that § 14 Abs. 4 Nr. 4 demands of an ordinary invoice, nor the time of supply. That is the umsatzsteuerlich minimum only. Record-keeping obligations under the GoBD and the income-tax side of the business do not disappear because the VAT side was simplified, and almost every Kleinunternehmer numbers invoices anyway — a business customer's bookkeeper expects a number, and an unbroken sequence is the cheapest evidence that nothing was removed. § 34a itself keeps §§ 33 and 34 UStDV untouched and applies § 31 correspondingly.

Second, the reference. The statute asks for a reference to the exemption, not for a magic formula. A line such as "Gemäß § 19 UStG wird keine Umsatzsteuer berechnet" does the job; so does the English equivalent on a document written in English, provided the German provision is named. What is not optional is the absence of a tax line. § 14c UStG is unforgiving here: a business that shows a tax amount it does not owe owes that amount to the Finanzamt on the strength of the document alone, and getting out of it means correcting the invoice and, in the § 14c Abs. 2 case, applying to the Finanzamt in writing. For a Kleinunternehmer this is the single most expensive mistake available, and it is always a formatting mistake. The general list of particulars for a taxable invoice is set out on the mandatory invoice particulars page.

No Vorsteuer, and what that costs

§ 15 Abs. 2 Satz 1 Nr. 1 UStG excludes the Vorsteuerabzug for goods and services used to make exempt turnovers, and the exceptions in § 15 Abs. 3 do not reach § 19. So the Umsatzsteuer on everything the business buys — the laptop, the van, the subcontractor's invoice, the software subscription — is a cost, not a claim. § 19 Abs. 6 adds one carve-out in the other direction: the exemption does not cover intra-Community supplies of new vehicles.

Whether that trade is worth taking is arithmetic, and it turns on who the customers are. A business selling to consumers keeps a price advantage, because the customer pays the same and no tax leaves the business. A business selling to other businesses gains nothing from the exemption — the customer would have recovered the tax anyway — and loses the input tax on its own purchases. A business about to invest heavily loses the most. This is exactly the calculation a Steuerberater does in an afternoon, and it is the reason § 19 Abs. 3 exists.

E-Rechnung: receiving is already compulsory, issuing is not

This is the part of the topic where the answer is genuinely two-sided, and where guessing is expensive. Since 1 January 2025 § 14 Abs. 1 UStG defines an E-Rechnung as an invoice issued, transmitted and received in a structured electronic format that permits electronic processing and conforms to EN 16931. A PDF sent by e-mail is no longer an electronic invoice in that sense; it is a "sonstige Rechnung".

Receiving. The BMF's questions-and-answers page on the mandatory e-invoice, at the March 2026 state of the text, answers this without qualification. Since 1 January 2025 every domestic business must be able to receive an E-Rechnung, and no exceptions are provided, because exceptions would create boundary problems. The same page names Kleinunternehmer explicitly: they are exempt from issuing an E-Rechnung but must nevertheless be able to receive one. It also states what "able to receive" means at the minimum — an e-mail inbox is enough. Your supplier does not need your agreement to send you one, because § 14 Abs. 1 Satz 5 UStG drops the consent requirement wherever the supplier is under the issuing duty of § 14 Abs. 2 Satz 2 Nr. 1.

Issuing. The last sentence of § 34a UStDV says it plainly: an invoice under that provision may, in departure from § 14 Abs. 2 Satz 2 UStG, always be transmitted as a "sonstige Rechnung". The BMF page lists services supplied by Kleinunternehmer among the cases where an invoice need not be issued as an E-Rechnung. So a Kleinunternehmer may go on sending paper or PDF for its own § 19 turnover, and this exemption is not a transitional one that expires — it sits in the regulation, not in the transitional provision. What does expire is the general transition in § 27 Abs. 38 UStG, which lets other businesses send paper or an unstructured electronic format until 31 December 2026, extends that to 31 December 2027 for a business whose Gesamtumsatz in the preceding calendar year was not more than 800 000 euro, and allows agreed EDI procedures until 31 December 2027.

Three edges deserve caution rather than confidence. The BMF's own page notes that a Kleinunternehmer switching to Regelbesteuerung becomes obliged to issue E-Rechnungen from that point, subject to the other conditions — so the exemption follows the status, and the status can change mid-year under the 100 000 euro rule above. The detailed administrative position lives in the BMF-Schreiben of 15 October 2024 and 15 October 2025 rather than in the FAQ, and professional bodies have publicly asked for further clarification on how the Kleinunternehmer rules and the e-invoice rules interlock. And a planned transaction reporting system is signalled in the same BMF material as something that will be legislated later, with the current rules to be examined again at that point. Treat the two propositions above — receive yes, issue no — as settled, and treat anything at the edges as a question to put to your Steuerberater with your own facts in front of them. Our German e-invoice page tracks the dates, and XRechnung vs ZUGFeRD explains the two formats you are likely to be sent.

One more practical point on receiving. In a hybrid format such as ZUGFeRD the structured XML part is now the leading part: where the XML and the visible image differ, the XML governs. Reading the file rather than the picture is therefore not a convenience, it is where the legally relevant figures are. You can check any file you have been sent with the free e-invoice checker without an account.

How KRONENWERK handles this

SUPPORTED WITH LIMITATIONS KRONENWERK issues Kleinunternehmer invoices without Umsatzsteuer and carrying the required reference to § 19 UStG, and it checks the § 14 UStG particulars before an invoice is given its number. It issues and validates XRechnung and ZUGFeRD against EN 16931 and the German CIUS before numbering, and reads incoming ZUGFeRD, XRechnung, Factur-X and UBL files into bills with the original file attached — which is the whole of what a Kleinunternehmer needs on the receiving side. Issued documents are frozen with gap-free numbering; corrections are credit notes. Application and database are hosted in Frankfurt with a public Auftragsverarbeitungsvertrag. Not done: there is no DATEV interface and no SKR03 or SKR04, no ELSTER filing of any kind — so no Umsatzsteuervoranmeldung is submitted from here, though a Kleinunternehmer generally does not file one at all, since § 19 Abs. 1 Satz 2 UStG disapplies the declaration duties of § 18 Abs. 1 bis 4 — no payroll, and no tax advice. Four plans from 29 € a month on the pricing page; there is no free plan and no trial. See also invoices and the Germany page.