Zeppol / Guides

E-invoicing for small businesses in Germany: what actually applies

Last updated 13 September 2026

The short answer first: as a small business under §19 UStG you do not have to issue e-invoices, and §34a UStDV says so expressly. You still have to be able to receive them, since 1 January 2025, with no exception. Two separate obligations, and confusing the two is why this question gets answered wrongly so often.

Why small businesses are exempt from issuing

The general e-invoicing obligation in §14(2) sentence 2 UStG covers taxable supplies between domestic businesses. Small businesses under §19(1) UStG sell without VAT: they show no VAT and deduct no input tax. With the 2024 Annual Tax Act the legislator clarified in §34a UStDV that an invoice for such supplies may always be transmitted as an "other invoice" within the meaning of §14(1) sentence 4 UStG, by way of derogation from the e-invoicing obligation that otherwise applies. In plain terms: you may keep sending PDFs or paper, and a structured EN 16931 e-invoice is not prescribed for your own outgoing invoices.

That is a deliberate exemption written into its own provision, not a loophole. It applies whether your customers are businesses or private individuals, and regardless of the size of any single invoice.

What your invoice still has to say

Being exempt from the e-invoicing obligation does not exempt you from proper invoicing. §34a UStDV lists the mandatory details for a small-business invoice: the full name and address of both parties, your tax number or VAT identification number, the issue date, the quantity and nature of the supply, the consideration, and an express note that the supply is exempt under §19 UStG. Without that note the invoice is incomplete, whatever format it is sent in.

When the exemption ends

The small-business scheme itself has had higher limits since 1 January 2025: 25,000 euros of prior-year turnover instead of 22,000, and 100,000 euros of current-year turnover instead of 50,000, raised by the 2024 Annual Tax Act. What also changed is how exceeding them works: if your turnover passes the 100,000 euro limit during the year, you lose small-business status immediately for the turnover above it, rather than at the next turn of the year as under the old rules.

Once you become ordinarily liable for VAT, losing small-business status also removes the issuing exemption in §34a UStDV. From then on you count like any other business and run into the same deadlines as everyone else: until the end of 2026 any issuer may still send an "other invoice" with the recipient's consent, until the end of 2027 the same holds for issuers with prior-year turnover up to 800,000 euros, and from 1 January 2028 the e-invoicing obligation applies with no turnover limit at all. Those deadlines are covered in Germany's 2027 mandate.

Should you issue e-invoices voluntarily anyway?

Some small businesses will not get to decide this themselves: certain business customers, particularly larger companies and public sector buyers, now ask for structured invoices regardless of whether the issuer is legally obliged to send them. In that case what your customer needs counts, not only what the law prescribes. How often it comes up depends heavily on who you sell to; for a Shopify store selling mostly to private consumers it rarely does.

What this has to do with your Shopify store

As long as you are a small business, the issuing obligation does not reach you, and Zeppol has nothing to do for your own sales yet. What does reach you today is the receiving side: invoices from your suppliers, software vendors or agencies can already arrive as e-invoices, which is covered in receiving e-invoices in Germany. And if your store grows past the small-business limits, which every growing store eventually does, the normal e-invoicing obligation applies from that point with the 2027 and 2028 deadlines. Zeppol turns your Shopify B2B orders into a valid e-invoice once that obligation starts for you, whether that is tomorrow or in a few years.

Read on

• Receiving e-invoices in Germany: the obligation that already applies to you, small business or not.
• Germany's 2027 mandate: the sending obligation, deadlines and thresholds for everyone else.
• XRechnung vs ZUGFeRD: the difference between the two formats.
• XRechnung for Shopify: the pure XML format in detail.
• ZUGFeRD for Shopify: the PDF with the structured data inside it.
• Peppol for Shopify: the network e-invoices are delivered over.

Frequently asked questions

This guide is general information for Shopify merchants, not tax or legal advice. Deadlines, exemptions and requirements can change. Confirm your own obligations with a qualified tax adviser. Sources: §34a UStDV, §19 UStG as in force from 1 January 2025 under the 2024 Annual Tax Act, and the Federal Ministry of Finance's e-invoicing FAQ, retrieved on 22 August 2026.