Kleinunternehmer invoice: what to write since 2025
Short answer: Since 2025, invoices from German small businesses under the Kleinunternehmer rule follow § 34a UStDV. They need both parties' names and addresses, your tax number, the issue date, a description of the service, the total amount and a note that the § 19 UStG exemption applies. You must not show VAT, and you never have to issue e-invoices.
When you register as a freelancer in Germany, the tax registration form asks whether you want to use the small business rule, the Kleinunternehmerregelung. Many newcomers tick yes, because it means no VAT returns and no VAT on invoices. What the form does not explain is what your invoices then have to look like. And since 1 January 2025, the answer has changed.
Under the old rules, the tax office simply did not collect VAT from small businesses. Since 2025, their sales are formally exempt from VAT, and their invoices have their own short list of requirements in § 34a of the VAT Implementing Ordinance. Templates floating around online often predate this. They are not wrong, just heavier than needed.
What a Kleinunternehmer invoice must contain
§ 34a UStDV lists six items:
- Your full name and address and those of your client.
- Your tax number (Steuernummer), your VAT ID or your small business ID number.
- The date of issue.
- A description of the goods, or the type and scope of the service.
- The total price and a note that the small business exemption applies.
- For self-billed invoices, the word „Gutschrift“.
There is no requirement for an invoice number or a date of supply. That is the biggest difference from a standard invoice, whose ten details are in the article on German invoice requirements. Put both on your invoices anyway. You need the number for your own bookkeeping, and some corporate clients reject invoices without one out of habit, even though they should not.
A sample invoice in English
Invented example: Tomás Rivera, a Spanish photographer living in Cologne, uses the small business exemption. He invoices a German architecture firm for a shoot.
- Architectural photo shoot, office building, 1 day
- €950.00
- Image editing, 25 photos
- €300.00
- Date of supply
- 28 September 2026
- Note
- Gemäß § 19 UStG wird keine Umsatzsteuer berechnet. / No VAT charged, small business exemption.
- Total due
- €1,250.00
Fictional example. Header with both full addresses and Tomás's tax number 217/123/45678.
No net amount, no VAT rate, no VAT line. Just the total and the exemption note.
The limits: €25,000 and €100,000
Whether you qualify depends on § 19 UStG. Your total turnover must not have exceeded €25,000 in the previous year and must not exceed €100,000 in the current year. Both figures are net and based on payments actually received.
| Criterion | Until 2024 | From 2025 |
|---|---|---|
| Previous-year limit | €22,000 | €25,000 |
| Current-year limit | €50,000 (forecast) | €100,000 (hard cap) |
| Calculated | including VAT | net |
| Legal effect | VAT not collected | sales exempt |
| Own invoice rule | § 34a UStDV |
Source: § 19 UStG in each version, § 34a UStDV
The €100,000 is now a hard line during the year, not a forecast. The sale that takes you over it is already taxable, and so is everything after it. Earlier invoices stay as they are. If you start your business during the year, there is no previous year to look at. According to the Finance Ministry’s guidance of 18 March 2025, the €25,000 limit then applies in the year you start.
So the rule usually ends quietly. Someone who earns €31,000 in 2026 is out from 1 January 2027, because the previous-year figure is above €25,000. Very few freelancers ever reach the €100,000 line within a single year.
Kleinunternehmer and e-invoicing
This is where small businesses have it easy. § 34a UStDV explicitly allows their invoices to be sent as plain PDFs or paper at any time, including after 2028 when e-invoicing becomes mandatory for almost everyone else. You may send an e-invoice voluntarily, but you never have to.
Receiving is different. Since 1 January 2025, every business in Germany must be able to receive e-invoices, small businesses included. An email inbox is enough. The article on how to receive e-invoices explains what to do with the XML file, and the full timeline is under e-invoicing in Germany.
One more practical point. Keep a simple turnover list per year, based on the date money arrived. The limits are calculated on payments received, so that list is all you need to see in good time whether the €25,000 line for next year is getting close.
The trap: services you buy from abroad
Here is something the registration form does not mention. Online ads, software subscriptions and cloud services often come from companies in Ireland, the Netherlands or the US. Their invoices to you show no VAT and a reverse charge note instead. As a business, you then owe German VAT on that amount, and that includes Kleinunternehmer.
Regular VAT payers deduct the same amount as input VAT, so the net cost is zero. Small businesses cannot deduct anything. For €200 a month in online ads, that means €38 of VAT a month you must report and pay, and a VAT return for each month in which it happens. Many newcomers find out during their first contact with the tax office. The mechanism is explained in the article on the reverse charge invoice.
Common mistakes
The expensive one is charging VAT out of habit. If 19 % appears on your invoice, you owe it under § 14c UStG. You get it back only after correcting the invoice, as described under cancel or correct an invoice.
Second, forgetting the note. It takes one line. Without it, your client cannot tell why there is no VAT, and a careful accounts department will ask.
Third, copying the reverse charge format for EU clients. Your own invoices to a company in Amsterdam do not get the reverse charge note and VAT IDs the way a regular VAT payer’s would. § 19 UStG excludes that. Whether the service is taxable in the other country then depends on that country’s rules, and for regular foreign work a short conversation with a tax adviser is worth it.
Is it worth giving up the exemption?
Sometimes. If most of your clients are businesses that deduct VAT anyway, charging VAT costs them nothing, and you gain the right to deduct VAT on your own purchases. On a €2,000 laptop that is about €319. If you mostly sell to private clients, the exemption usually wins, because you can be 19 % cheaper. Opting out binds you for at least five calendar years under § 19(3) UStG, so it is not a decision for one big purchase.
Once your invoice is ready, choose „Small business exemption“ in the invoice checker. It checks the six items from § 34a and confirms that no e-invoice is needed. If you later want invoices generated automatically from your own shop or portal, OnlineBuilders offers a free first technical consultation.
Check an invoice for mandatory details: Tick what your invoice contains.
Questions people ask
What exactly should the exemption note say?
The law does not prescribe wording. Common versions are „Gemäß § 19 UStG wird keine Umsatzsteuer berechnet“ or, in English, „No VAT charged, small business exemption under § 19 UStG“. Using both on a bilingual invoice is a good habit.
Do I need an invoice number as a Kleinunternehmer?
§ 34a UStDV does not list one. Use one anyway, because you need to match payments and many clients expect it. A simple sequence such as 2026-001, 2026-002 works.
What if I accidentally charged 19 % VAT?
Then you owe that amount to the tax office under § 14c UStG, even though your sales are exempt. You can correct the invoice and reclaim it. Until then the money belongs to the tax office, not to you.
Do I need a VAT ID as a Kleinunternehmer?
Not for invoicing German clients, your tax number is enough. A VAT ID is useful if you buy services from other EU countries, because suppliers there ask for it. You can apply for one at the Federal Central Tax Office.
