Kleinunternehmer Rules: Mandatory Invoice Fields Under §19 UStG
This article doesn't replace tax advice. It describes the general legal position — check edge cases with your Steuerberater.
Kleinunternehmer invoices have their own, shorter list of mandatory details
Since 1 January 2025, invoices from a Kleinunternehmer under §19 UStG follow their own rules (§34a UStDV) instead of the full list in §14 UStG. They must contain: the full name and address of both the supplier and the customer; your tax number or VAT ID (or, if you have one, your Kleinunternehmer identification number); the date of issue; the quantity and type of goods or the scope and type of service; and the amount charged, as a single total. Not required: a sequential invoice number, the date of delivery or service, or any VAT rate or amount — no VAT is charged in the first place. Many businesses still number their invoices and state the service date anyway, because it keeps the bookkeeping clean.
The mandatory §19 UStG notice
Every Kleinunternehmer invoice must say that the small-business exemption applies (§34a No. 5 UStDV), for example: "Gemäß §19 UStG wird keine Umsatzsteuer berechnet" (No VAT is charged under §19 UStG). This is a required part of the invoice, not a courtesy — and it also stops business customers from assuming a mistake when an invoice arrives without VAT.
The new €100,000 threshold since 2025
Since the §19 UStG reform took effect on 1 January 2025, two thresholds apply: prior-year revenue must not have exceeded €25,000, and current-year revenue must not exceed €100,000. The key change from the old rules concerns the second figure: if you actually cross €100,000 during the year, Kleinunternehmer status ends immediately — standard VAT applies from the exact transaction that crosses the line, while everything before it stays retroactively tax-exempt. It's based on actual revenue, not what you expected at the start of the year, and there's no transition period. If you're operating close to this line, it's worth knowing exactly where you stand — a quick check is enough. In the year you start your business, the tax authority applies a limit of €25,000 for that year — not €100,000 — and it isn't pro-rated to a full year (BMF letter of 18 March 2025).
What about e-invoices?
Kleinunternehmer are permanently exempt under §34a UStDV from the obligation to issue e-invoices (XRechnung/ZUGFeRD) — that stays true even once the e-invoicing mandate is fully in effect in 2028. One obligation still applies, though: since 1 January 2025, every business, including Kleinunternehmer, must be able to receive and archive incoming e-invoices. If you're not sure which rule applies to your situation, three questions will give you a clear answer.
Getting close to the threshold?
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