The Kleinunternehmer rule (§19 UStG) & the e-invoice
Even those who show no VAT are affected by the e-invoicing mandate — at least when receiving. What applies to Kleinunternehmer from 2025, briefly and clearly.
Receiving: applies from 2025 to everyone — including Kleinunternehmer
The obligation to receive e-invoices in domestic B2B business has applied since 1 January 2025 with no exception for Kleinunternehmer. A Kleinunternehmer under §19 UStG that receives an e-invoice from another business must be able to receive it and retain it in a GoBD-compliant way. A pure PDF inbox is no longer enough for this — the structured XML must be archived in a processable form.
Issuing: relaxed, but not a free pass
For issuing there are relaxations: Kleinunternehmer invoices may, during the transition, continue to be issued in another form, and for certain cases an e-invoice is not mandatory. This does not, however, exempt you from the general trend — business customers increasingly demand the structured invoice, and those who can supply it avoid follow-up queries.
Important: Kleinunternehmer show no VAT (§19 UStG). An e-invoice represents this correctly — with the category 'tax exemption / no VAT shown' and the appropriate mandatory note, instead of a tax rate.
| Process | Mandatory from 2025 | What CoolHanX does |
|---|---|---|
| Receive e-invoices | yes, without exception | upload/inbox, validation, GoBD archive |
| Retain e-invoices | yes, 8 years, tamper-proof | WORM archive with checksum |
| Issue e-invoices | relaxed rules during the transition | optional, without VAT shown under §19 |
| Show VAT | no (§19) | the 'no VAT' category + mandatory text automatically |
What this means in practice
Even if, as a Kleinunternehmer, you still write classic invoices today: for receiving you now need a way to accept, validate and archive structured e-invoices in an audit-proof manner. That is exactly what the free entry plan from CoolHanX delivers — receiving, validation and the GoBD archive are included, without VAT complexity.
Frequently asked questions
Do I, as a Kleinunternehmer, have to be able to receive e-invoices?
Yes — the obligation to receive has applied since 2025 without exception for domestic B2B transactions.
Do I have to issue e-invoices myself?
During the transition there are relaxations; the obligation and deadlines follow the general rules. Business customers increasingly ask for the structured form.
Do I show VAT?
No — under §19 UStG with no VAT shown. The e-invoice represents this with the correct category and a mandatory note, not with a tax rate.
Does this cost me anything?
Receiving, validation and the GoBD archive are included in the permanently free plan (a monthly document allowance).
What §19 UStG governs
The Kleinunternehmer rule (§19 UStG) exempts businesses with low turnover from levying VAT: they show no VAT and, in return, deduct no input VAT. What is decisive are the turnover limits for the previous and current year named in the law (check the specific amounts with your tax firm, as they have been adjusted). On the invoice, instead of a tax rate, a note referring to the Kleinunternehmer rule (§19 UStG) appears.
| Process | Mandatory from 2025 | in CoolHanX |
|---|---|---|
| Receive e-invoices | yes, without exception | upload/inbox, validation, archive |
| Retain for 8 years | yes | WORM archive with checksum |
| Issue e-invoices | relaxed rules during the transition | optional, without VAT shown |
| Show VAT | no (§19) | the 'no VAT' category + mandatory note automatically |
The often overlooked point: receiving first
Even those who show no VAT themselves must, from 2025, be able to receive and archive e-invoices — the obligation to receive has no Kleinunternehmer exception. In practice this means: first you need a way to accept structured documents and retain them in a GoBD-compliant way. That is exactly what the free entry plan delivers, without VAT complexity.
Related topics
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