Small-business invoicing in Germany: How it works without VAT (§ 19 UStG)

Germany's small business scheme (Kleinunternehmerregelung) is the best friend of many freshly minted solo entrepreneurs: no VAT on your invoices, no advance returns, less bureaucracy. But that is exactly why the same question always comes up: What does an invoice have to look like when I am not allowed to charge VAT?

The answer is simpler than its reputation – as long as you keep three things in mind: knowing the correct thresholds, adding the mandatory note and understanding which details you can skip. We walk you through all of it, step by step.

Do you even qualify as a small business owner?

Since the reform that took effect on 1 January 2025, a dual annual threshold applies:

• Your revenue in the previous year was at most 25,000 euros, and
• your revenue in the current year stays at most 100,000 euros.

Only then are your sales exempt from VAT under § 19 Abs. 1 UStG. Both thresholds count net amounts – a notional VAT amount is no longer added – and they apply to your total revenue from all activities, calculated on payments actually received (cash basis, not invoice date).

Two important special cases:

1. Starting mid-year: In your first year of business there is no previous year's revenue – you automatically qualify as a small business owner, with no forecast required. What matters is simply your actual revenue during that first year measured against the 25,000-euro threshold. If you exceed it, exactly that sale becomes subject to standard taxation – everything before it stays tax-free.
2. Crossing the 100,000-euro limit: Here too you are not thrown out retroactively for the whole year, but from the individual sale that crosses the line. From that point on you charge regular VAT on new invoices and file advance returns. Which is why keeping an eye on your revenue pays off.

By the way: you can also voluntarily opt out of the small business scheme and charge regular VAT (§ 19 Abs. 3 UStG). That makes sense if your clients are mostly businesses that deduct the VAT anyway. The opt-out binds you for at least five calendar years and must be declared to the tax office by the end of February of the second following year – when in doubt, get advice.

The mandatory note: how to phrase it correctly

Every small-business invoice must state that the small business VAT exemption applies (§ 34a UStDV). This wording has proven itself:

Gemäß § 19 Abs. 1 UStG wird keine Umsatzsteuer berechnet. (No VAT is charged in accordance with § 19 Abs. 1 UStG.)

Shorter variants such as "Kein Umsatzsteuerausweis, da steuerfreier Kleinunternehmer gemäß § 19 UStG" ("no VAT shown, as a tax-exempt small business under § 19 UStG") are also accepted by the tax authorities – what matters is that the exemption is clearly recognisable.

The sentence belongs exactly where the tax block would otherwise sit – where net amount, tax rate and tax amount normally appear. Here is the complete block:

Items:
  Coaching session (60 min.) ............... €90.00

Total:                                     €90.00

Gemäß § 19 Abs. 1 UStG wird keine Umsatzsteuer berechnet.

So you can simply show the amount as the final total in one sum – no split into net and gross, because both are identical.

What still belongs on your small-business invoice

Since 2025 there is finally a dedicated list of mandatory invoice details for small businesses (§ 34a UStDV). Accordingly, your invoice needs:

• your full name and address,
• the customer's name and address,
• your tax number (Steuernummer) or VAT ID (USt-IdNr.),
• the issue date,
• the quantity/scope and type of service,
• the total amount in one sum, and
• the small-business note from above.

Interestingly, a sequential invoice number and the exact period of service are no longer on the mandatory list since 2025. We still strongly recommend both – without a numbering scheme you quickly lose track, and payment references like "Invoice 2026-014" make life noticeably easier for you and your customers.

For amounts up to 250 euros gross, a simplified small-amount invoice with fewer details is sufficient – but even there, the small-business note must never be missing.

What you can skip

And here it gets pleasant: a few things that are routine on regular invoices are things you as a small business owner don't need:

• No VAT advance returns and no annual VAT return. Without charged VAT, these declaration obligations disappear completely – the income-surplus statement (Einnahmen-Überschuss-Rechnung, EÜR) for income tax purposes is unaffected.
• No tax rates per line item. Since no tax is charged, the breakdown by tax rate falls away too.
• Gross = net. Your customer pays exactly the amount you bill – no surcharge, no input tax deduction on their side. Keep in mind, though: you cannot deduct input tax either; you pay supplier invoices gross.

E-invoicing: what small business owners need to know now

Here the reform had a genuinely nice gift for small businesses:

• Since 1 January 2025 you must – like all businesses – be able to receive, read and archive structured e-invoices in B2B dealings when a customer sends you one.
• On the issuing side, small businesses stay permanently free: your § 19 invoices may always be sent as paper or PDF invoices – without the customer's consent and without any deadline (§ 34a UStDV).
• The well-known transition periods mainly concern businesses taxed under the standard rules: they get a transition phase until the end of 2026, smaller companies under 800,000 euros in revenue may send "other" invoices until the end of 2027, and from 2028 essentially everyone must invoice electronically in a structured format. None of that touches you unless you opt into standard taxation.

So your small-business invoice happily keeps going out as a PDF – the § 19 exemption and the e-invoicing duties pass each other by.

Typical mistakes on small-business invoices

These stumbling blocks are the ones we see most often:

• Forgetting the note. Without the § 19 sentence the invoice is formally incorrect – correct and reissue it immediately if in doubt.
• Writing "7% or 19%" anyway. If you invoice tax-free, you must not show VAT – otherwise you owe the tax office the amount shown under § 14c UStG, even though your customer cannot deduct it.
• Not watching the thresholds. The 25,000/100,000-euro limits are hard cutoffs: whoever crosses them switches to standard taxation from exactly that sale onwards – and must show VAT and file advance returns from then on.
• Duplicate invoice numbers. Even though numbering is no longer strictly mandatory: if you number, number sequentially and uniquely – ideally with a year prefix like "2026-014".

Stay a small business – but invoice like a pro

The small business scheme is not a stopgap; it is a legitimate business model. It deserves tools that take it seriously: invoices with an automatically correct § 19 note, numbering schemes that never duplicate, and an eye on your revenue that warns you before you hit the limit.

That is exactly why we built Gewerber – an open-source platform for solo entrepreneurs in Germany where the small business scheme is not a hidden feature but the default path. Try it for free in the beta or take a look at the invoicing features.