Yes, as a German small business under section 19 of the VAT Act (UStG) you may issue invoices, and as a rule you must do so for business customers: section 14 (2) sentence 2 UStG requires an invoice within six months of the supply. The listed exemptions include tax-exempt supplies under section 4 nos. 8 to 29 UStG. Your invoice is shorter than an ordinary one. Section 34a of the VAT Implementing Regulation (UStDV) asks for five details that are always on it: the full name and address of both parties, your tax number or VAT identification number, the date of issue, the quantity and type of what you supplied, and the consideration as a single sum together with a reference to the small business exemption. A sixth is added only where your customer does the invoicing: the word "Gutschrift" (self-billing). No VAT appears on it, because your supplies are exempt under section 19 (1) UStG as long as your total turnover did not exceed 25,000 euros in the previous calendar year and does not exceed 100,000 euros in the current one. If you do show a VAT amount by accident, that can trigger a tax liability under section 14c (1) UStG; where you actually carried out the supply and the invoice went to a final consumer, no such liability arises according to the Federal Ministry of Finance.
That is why no invoice of mine starts life in Word any more. It always starts in the invoicing tool: that is where the number range runs, where changes stay traceable, and where the section 19 note sits once in the master data instead of being retyped into every file. What the path from inbox to draft looks like here is in AI Agent for Bookkeeping and Inbox, and the wider concept is on Hiring AI employees. This post deals with the document itself first, following the provisions cited below and the Federal Ministry of Finance letter of 18 March 2025. It is not tax advice for your particular case.
Are you even allowed to: with a trade registration, without one, as a private person
The question behind "can I invoice without a registered trade" is not whether you may send a document, but whether you are a taxable person. For VAT purposes that does not hang on a trade registration but on section 2 (1) UStG: any sustained activity carried out to earn income is commercial or professional, even without an intention to make a profit.
The third case is the dangerous one, because it looks so harmless. What applies here is not section 14c (1) UStG as for a small business, but section 14c (2) UStG: anyone who shows a VAT amount as a private individual without being entitled to do so owes it. The Federal Ministry of Finance names supplies by private individuals as an example. For a private sale a plain receipt with the date, the item, the price and both names is enough; there is no statutory form for it, and the only thing that matters is that no tax amount appears on it.
The mandatory details under section 34a UStDV
Section 34a sentence 1 UStDV lists six items. Five of them apply to every invoice covering supplies that are exempt under section 19 (1) UStG, the sixth only in self-billing cases.
- Full name and full address of the supplier and of the recipient. Both sides, not just yours.
- Your tax number, the VAT identification number or the small business identification number. One is enough, leaving all of them out is not an option.
- The date of issue.
- The quantity and type of the goods supplied in their commercial description, or the scope and type of the service. "Consulting" is not a type, "strategy workshop, one day" is.
- The consideration as a single sum, together with the reference to the exemption under section 19 UStG. Both sit in the same item: one figure, and next to it the reason why no tax follows.
- The word "Gutschrift", and only where your customer invoices for your supply (section 14 (2) sentence 5 UStG). If you invoice yourself, this item does not apply.
There is no prescribed wording for the reference in item 5. The Federal Ministry of Finance accepts colloquial wording as long as it is unambiguous, and gives "steuerfreier Kleinunternehmer" as an example. Equally clean: "Gemäß § 19 UStG wird keine Umsatzsteuer berechnet".
More interesting is often what is missing.
Up to 250 euros you may also issue a small-amount invoice under section 33 UStDV: fewer details, but still the reference to the exemption. What of this already belongs in the quote is covered in How to Write a Quote That Convinces.
Why there is no VAT on it, and what happens if there is
Since 1 January 2025 the small business rule is no longer a non-collection of tax but a genuine exemption under section 19 (1) UStG. Two things follow:
- You show no tax. Net and gross are the same figure for you. Present the price exactly that way, as one sum with the reference underneath.
- You deduct no input VAT. Section 15 (2) sentence 1 no. 1 UStG excludes the deduction for exempt supplies, and section 15 (3) sentence 2 UStG takes cases falling under section 19 out of the exceptions. The VAT you pay yourself is a cost.
And now the costliest mistake in this field: a line reading "plus 19 % VAT" left over from an old template. Anyone who states a tax amount they do not owe can end up owing it. Until the end of 2024 that ran through section 14c (2) UStG; since the reform the supply is exempt, so the incorrect tax statement in section 14c (1) UStG applies instead. The VAT application decree says so in as many words: an excessive tax statement also exists where a tax amount is stated on the invoice of a small business.
Where the liability does arise, the amount is due even if you never received it from the customer. It can be repaired by correcting the invoice towards the recipient; section 17 (1) UStG applies accordingly. And there is a relief many people do not know about: where you actually carried out the supply and the faulty invoice goes to a final consumer, no tax arises at all according to the same letter. So the first thing to check is who received the invoice.
The invoice number: what is required, and what you should do anyway
For VAT purposes section 34a UStDV asks for no invoice number. That does not make numbers irrelevant, because section 146 (1) AO sits alongside it: records must be made individually, completely, correctly, in good time and in an orderly manner. So assign numbers the way section 14 (4) no. 4 UStG describes them for the regular invoice: sequential, made up of one or more series of figures, assigned once and once only by the issuer. The core of it is uniqueness, not a single unbroken counter.
Three rules are enough to start with:
- A format you will still understand in five years, and no number twice. Year plus running number, so 2026-001, is boring and unambiguous. With several series, each one gets its own prefix.
- Do not overwrite an issued invoice without a trace. Section 146 (4) AO requires that the original content stays ascertainable and that later changes remain recognisable as such. What follows from that is a traceable correction route, not one prescribed mechanism. In my tool that route is cancellation and reissue.
- A procedure that records changes. It is not the file format that decides this, but whether someone can later see what was changed and when. That is where a hand-kept spreadsheet with no history and no second control fails. How retention and the GoBD work is in Bookkeeping Basics for the Self-Employed.
The thresholds, and what happens when you cross one
What counts is the total turnover under section 19 (2) UStG, and that is calculated on the basis of payments received: it matters when the money arrives, not when you wrote the invoice.
The 100,000-euro threshold is the unpleasant one, because it bites without warning. The Federal Ministry of Finance works the case through with dates (section 19.7 (1) UStAE): 20,000 euros of total turnover in the previous year, 80,000 euros so far in the current one, plus two further supplies.
Two things follow. First: it is not only the part above the line that becomes taxable, but the whole supply that crosses it, here the full 25,000 euros. Second: without the crossing, supply 1 would stay exempt even though the money only arrives in September. Because the threshold falls in July, that older payment falls under standard taxation too.
From the crossing supply onwards, VAT therefore belongs on the invoice, along with input VAT deduction and preliminary returns. If it is already sitting in the folder without tax, it has to be corrected. If you are unsure about your own figures, you do not have to work it out alone: the question fits into a call or a post in the community, and for the borderline case itself a tax adviser belongs in the room. If you can see the threshold coming, waiving the exemption under section 19 (3) UStG is the predictable alternative: irrevocable, and binding for at least five calendar years.
When the draft is created inside the invoicing tool
Most of the building sites in this post have nothing to do with the wording of the invoice and everything to do with where it is created. The section 19 reference is master data, the number range is a setting, the traceability of changes is something the tool promises. None of it comes for free: setup, permissions and an agreed process belong to it. Configured properly, the place clears three obligations at once, and what is left is the actual work: items, quantity, type, price.
That is the part Anton, my AI employee for offers and invoices, takes over here. Once a client says yes, he creates the contact, the offer and the invoice as a draft in Lexware Office, the tool he is connected to. Anyone on a different program builds the connection through an adapter on the same pattern: everything a draft, a test run before going live. You build that adapter once, and not alone: the community has people who have gone the same way with their own invoicing program, and a question in a call or a post is enough.
Two limits are hard-wired. First: he drafts, I approve. Nothing is finalised before I have said yes, and he names the consequences first, such as the invoice number that then becomes final. Second: no price without a source. If he finds two prices for the same service, he lists both with their origin and asks. How that fits into a one-person business is in AI for Freelancers: What Pays Off.
Frequently asked questions
Do I have to issue invoices at all as a small business?
Towards businesses and legal entities yes, within six months of the supply (section 14 (2) sentence 2 UStG). The exemption from the duty to invoice only covers supplies exempt under section 4 nos. 8 to 29 UStG, and your exemption comes from section 19. Towards private customers you are entitled to invoice but, outside services connected with land, not obliged to.
What do I write instead of the VAT?
A reference stating that the small business exemption applies (section 34a sentence 1 no. 5 UStDV). There is no fixed formula: colloquial wording is enough where it is unambiguous. The Federal Ministry of Finance's example is "steuerfreier Kleinunternehmer".
Do I need a sequential invoice number?
Section 34a UStDV does not ask for one. Your records still have to be traceable (section 146 AO), and in standard taxation at the latest section 14 (4) no. 4 UStG applies. So assign them from the start; several series of figures are allowed.
What do I do if I accidentally showed VAT?
As a rule you owe the amount shown, since 2025 as an incorrect tax statement under section 14c (1) UStG. You can put it right by correcting the invoice towards the customer; section 17 (1) UStG applies accordingly. If the invoice went to a final consumer and you actually carried out the supply, no such tax arises in the first place, according to the letter of 18 March 2025.
Can I invoice without a registered trade?
For VAT purposes the registration is not what matters, section 2 (1) UStG is. Freelancers need no trade registration and still issue invoices. Anyone selling something privately on a one-off basis issues a receipt with no VAT on it, otherwise they owe it under section 14c (2) UStG.
Do I have to issue e-invoices as a small business?
No. Section 34a sentence 4 UStDV expressly allows your invoice to be transmitted as an "other invoice" at all times, so as a PDF or on paper. You have had to be able to receive e-invoices since 1 January 2025, with no grace period. Deadlines and exemptions are in German E-Invoicing: Dates and Exemptions.
Where to go from here
Take the last invoice you wrote, or the free invoice template if you have none yet, and check it against the list in section 34a UStDV. Then settle two things: where your invoices will be created from now on, and how your numbers are built. Those two decisions clear more obligations at once than any wording.
If what is left afterwards is the actual work, items and prices, the step before it is worth a look: Which Tasks You Can Hand Off to AI and Bringing AI to a Small Business. The finished offers-and-invoices employee, course included, is in my community Claude Practitioners.
