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.

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
• ZUGFeRD – a hybrid format combining a PDF with embedded XML

A classic PDF invoice, by contrast, has only counted as an "other invoice" (sonstige Rechnung) since 2025. For more on the formats, 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.

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.

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. An AI-powered bookkeeping tool reads e-invoices automatically and files them correctly.

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:

• Since 01/01/2025: Receiving obligation for all businesses (incl. small businesses).
• Until 31/12/2026: All businesses may continue to send paper/PDF invoices (with the recipient's consent).
• Until 31/12/2027: Extended deadline for businesses with prior-year turnover up to €800,000.
• From 01/01/2028: E-invoicing becomes binding for all B2B transactions subject to the issuing obligation – small businesses remain exempt.

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 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.

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.
• 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.

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.