E-invoicing: which exemptions exist
Who is exempt from issuing – and who must still be able to receive
Key takeaways
- Receiving is mandatory: Since 1 January 2025 every domestic business must be able to receive e-invoices – there is no exception to this.
- Small amounts: Small-amount invoices up to €250 gross and transport tickets may still be issued as "other invoices" (e.g. PDF).
- B2C & abroad: Invoices to private individuals (B2C) and to recipients without a domestic seat are not covered by the e-invoice obligation.
- Small businesses: Small businesses (§ 19 UStG) do not have to issue e-invoices but must – like everyone – be able to receive them.
Principle: receiving vs. issuing
Important first: the exemptions always concern the obligation to issue an e-invoice. The obligation to be able to receive e-invoices has applied since 1 January 2025 without exception to all domestic B2B businesses – including small businesses. An email inbox is enough to receive an XRechnung or ZUGFeRD file.
These exemptions exist
Exempt from the obligation to issue a structured e-invoice are:
- Small-amount invoices up to €250 gross (§ 33 UStDV).
- Transport tickets used as an invoice (§ 34 UStDV).
- Services to private individuals (B2C) – there is no e-invoice obligation here.
- Certain VAT-exempt transactions under § 4 Nos. 8–29 UStG (e.g. letting, medical services).
- Invoices to recipients without a domestic seat (foreign transactions).
Special case: small businesses
Small businesses under § 19 UStG were explicitly exempted from the obligation to issue an e-invoice by the 2024 Annual Tax Act. They may continue to issue their invoices as "other invoices" (e.g. PDF or paper). The obligation to receive, however, still applies to them too – a business partner may send them an e-invoice.
Transition periods until 2028
Even without a permanent exemption there are transition periods: until the end of 2026, paper or PDF invoices may still be sent for B2B transactions (with the recipient’s consent). Businesses with prior-year turnover up to €800,000 even have until the end of 2027. From 2028 the issuing obligation applies to everyone without a transition rule.
Frequently asked questions
Who is exempt from the e-invoice obligation?
Exempt from issuing are, among others, small-amount invoices up to €250, transport tickets, B2C services, certain exempt transactions (§ 4 Nos. 8–29 UStG) and small businesses. The obligation to receive e-invoices, however, applies to all.
Do small businesses have to issue e-invoices?
No. Small businesses under § 19 UStG are exempt from the issuing obligation but must be able to receive e-invoices.
Does the obligation apply to invoices to private customers?
No. Invoices to private individuals (B2C) are not covered. The obligation only concerns transactions between domestic businesses (B2B).
Are small-amount invoices exempt?
Yes. Small-amount invoices up to €250 gross (§ 33 UStDV) and transport tickets may still be issued as "other invoices".
How long may I still send PDF invoices?
In B2B generally until the end of 2026, and with prior-year turnover up to €800,000 even until the end of 2027 – in each case with the recipient’s consent.
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