Kleinunternehmer under §19 UStG are exempt from issuing e-invoices — but not from receiving them. Since 1 January 2025 every German business, including a §19 small business, must be able to accept a structured e-invoice. And a §19 invoice must never show VAT: if it does, you owe that VAT to the tax office even though you never collected it. This guide covers the thresholds as they stand after the Jahressteuergesetz 2024, what belongs on a §19 invoice, and the one Shopify tax setting that quietly breaks everything.
The thresholds changed in 2025
The §19 limits were raised and their logic changed. You are a Kleinunternehmer if:
- your total turnover in the previous calendar year did not exceed EUR 25,000, and
- your turnover in the current year does not exceed EUR 100,000.
The second limit is the one that catches people. It is no longer a forecast you make in January — it is a hard ceiling that applies during the year. The moment your turnover crosses EUR 100,000, you leave the §19 scheme immediately, for the very transaction that breaches it. Invoices issued before that point stay VAT-free; from that transaction onward you charge VAT.
That is a real operational problem for a shop. There is no grace period and no "from next month". If you are anywhere near the ceiling, you need to know your running annual turnover before you take the next order, not at the end of the quarter.
Exempt from issuing, obliged to receive
The e-invoicing mandate (see our 2027/2028 timeline) splits into two obligations, and small businesses sit on different sides of each.
Receiving has been mandatory for everyone since 1 January 2025. A B2B supplier may send you an XRechnung or ZUGFeRD file and you must be able to accept it. In practice this means a working, monitored email address — nothing more is legally required. You do not need software to open it, though you will want it.
Issuing is where §19 businesses are excused. §34a UStDV permits Kleinunternehmer to keep issuing a "sonstige Rechnung" — an ordinary invoice, including a plain PDF or paper — instead of a structured e-invoice. That exemption is not time-limited by the 2027 and 2028 dates that apply to everyone else.
"Permitted" is not "advisable". Your B2B customers are moving to automated invoice processing, and a PDF that has to be typed in by hand is friction they will notice. Issuing ZUGFeRD costs a §19 business nothing extra and makes you the easy supplier to deal with.
What a §19 invoice must and must not contain
All the usual §14 Abs. 4 UStG particulars still apply: your full name and address, your customer's, your tax number or VAT ID, invoice date, a gapless invoice number, the quantity and description of what was supplied, and the date of supply.
Two differences matter:
- No VAT rate and no VAT amount. Not "0%", not a separate line showing zero — the tax simply is not shown.
- A note explaining why. The law does not dictate the wording. The standard formulation is: "Gemäß § 19 UStG wird keine Umsatzsteuer berechnet." ("In accordance with §19 UStG, no VAT is charged.")
Get the first one wrong and §14c UStG applies: an unberechtigter Steuerausweis, an unauthorised statement of tax. You owe the amount you printed, whether or not your customer ever paid it, and correcting it means issuing a corrected invoice and — if the customer already deducted that VAT as input tax — an adjustment on their side too. This is the single most expensive mistake available to a small business writing its own invoices.
The Shopify setting that breaks §19 invoices
Here is the conflict we see most often, and it is worth understanding before it happens to you.
Shopify's tax settings and your invoicing setting are two separate switches. If your store is configured to charge VAT on orders while your invoicing app is told you are a §19 small business, every order produces a contradiction: Shopify has collected tax on the order, and the invoice is legally forbidden from showing it.
There is no correct invoice to produce from that state. Silently dropping the tax would understate what the customer actually paid — the totals would not match the payment. Silently showing it would create a §14c liability. The only defensible behaviour is to refuse and tell you which setting is wrong, which is exactly what Rechna does: the invoice is withheld with a message naming the conflict, and nothing is issued until you either untick §19 or stop charging tax in Shopify.
Two ways out, depending on which setting is actually true:
- You really are a Kleinunternehmer. Then Shopify should not be charging tax. Set your product prices as gross prices with no tax applied and switch tax collection off for your regions.
- You have left the §19 scheme — by crossing a threshold, or by opting out voluntarily. Then untick the §19 setting, and your invoices start showing VAT from that point on.
Both are one-minute fixes. The reason to know about it in advance is that the failure surfaces at the worst possible moment: after a customer has paid and is waiting for an invoice.
Opting out on purpose
§19 is not always the better deal. You can waive it under §19 Abs. 3 UStG and be taxed normally, which binds you for five calendar years. That is worth considering if you sell mostly B2B (your customers deduct the VAT anyway, so your prices are effectively unchanged for them) or if you have large input VAT to reclaim — inventory, equipment, a shop build. As a Kleinunternehmer you cannot reclaim input tax at all.
Selling to consumers on thin margins usually points the other way: no VAT on your prices is a genuine competitive advantage.
Crossing the threshold, in practice
The transition is where records get messy. A checklist that keeps it clean:
- Watch the running total, not the calendar. The EUR 100,000 ceiling bites mid-transaction.
- Change the invoicing setting the same day. The §19 note must disappear from the first taxed invoice, and the VAT breakdown must appear.
- Do not reissue earlier invoices. They were correct when issued. An issued invoice is a booking record; it is corrected only by a Storno or a credit note, never edited (see correcting an invoice).
- Keep the numbering sequence. Leaving §19 does not start a new series. The same gapless sequence continues.
- Tell your tax adviser before, not after. The five-year lock on a voluntary waiver makes this hard to undo.
The short version
A §19 small business may keep issuing ordinary invoices indefinitely, must be able to receive structured e-invoices since January 2025, and must keep VAT off its invoices entirely — the note replaces the tax, it does not accompany it. The threshold to watch is EUR 100,000 in the current year, and it applies the moment you cross it. If your store charges tax while your invoicing says §19, no correct invoice exists: fix the setting, then reissue.
This is a plain-language summary, not tax advice. Thresholds and wording are matters for your Steuerberater, who will also tell you whether waiving §19 is worth it in your specific case.