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§19 UStG Guide

Kleinunternehmer Invoicing
in Germany: Full Guide

Germany's §19 UStG lets small freelancers skip VAT entirely, but only if you invoice correctly. Revenue thresholds, the right disclaimer, international clients, and what happens when you grow.

Last updated: 25 October 2026

A Kleinunternehmer is a self-employed person in Germany whose revenue was no more than €25,000 in the previous calendar year and does not exceed €100,000 in the current year. These limits have applied since 1 January 2025. Under §19 UStG, they charge no VAT, skip monthly Umsatzsteuervoranmeldungen, and add the disclaimer "Gemäß §19 UStG wird keine Umsatzsteuer berechnet" to every invoice instead.

What is a Kleinunternehmer?

A Kleinunternehmer ("small entrepreneur") is a self-employed person or freelancer exempt from charging VAT under §19 of the German VAT Act (Umsatzsteuergesetz, UStG). The exemption exists to reduce bureaucratic burden on people running small, early-stage, or side businesses: you don't charge VAT, you don't file monthly VAT returns, and you keep your paperwork simple.

You qualify as a Kleinunternehmer if:

Revenue is counted net and by payments actually received in the year, not by invoices issued. In your first year of self-employment there is no previous year to look at, so the €25,000 limit applies to what you actually earn in that year. Since 2025 it is no longer prorated or projected to a full year: starting in July, your limit for the rest of that year is still €25,000. If you go over it, the exemption ends from that invoice on. Until the end of 2024 the limits were €22,000 and €50,000, so older guides still quote those figures.

How to register as a Kleinunternehmer

There is no separate "Kleinunternehmer registration." It is a box you tick when you first register as self-employed in Germany.

When you submit the Fragebogen zur steuerlichen Erfassung (the tax registration questionnaire) to your local Finanzamt (either on paper or online via Elster), you will be asked whether your expected revenue qualifies you for the Kleinunternehmer exemption. If yes, tick yes.

If you are also required to register a trade (Gewerbe) at the Gewerbeamt, that is a separate step, but the Kleinunternehmer status is still determined by the Finanzamt, not the Gewerbeamt.

Your Finanzamt will issue you a Steuernummer (tax number), which you put on all your invoices. For clients in Germany this is all you need: no VAT ID, no monthly returns.

What goes on a Kleinunternehmer invoice

A Kleinunternehmer invoice looks almost identical to a normal invoice, with two important differences: there is no VAT line, and there must be a §19 UStG disclaimer. Here is the exact text required:

Gemäß §19 UStG wird keine Umsatzsteuer berechnet.

Translation: "No VAT is charged in accordance with §19 UStG."

You can place this disclaimer anywhere on the invoice: in the notes section, below the total, or in the footer. It just needs to be present and legible.

For clients in Germany you do not need a Umsatzsteuer-ID (VAT ID); your Steuernummer from the Finanzamt is sufficient. For EU business clients you need one for the reverse charge note, and you can get it from the Bundeszentralamt für Steuern without losing your Kleinunternehmer status. Do not leave a VAT ID field blank or with a placeholder; simply omit it from the invoice.

Kleinunternehmer vs VAT-registered: which are you?

FeatureKleinunternehmerVAT-registered
Charge VAT on invoicesNoYes (19% or 7%)
File VAT returns (Umsatzsteuervoranmeldung)NoYes (monthly/quarterly)
Reclaim input VAT on expensesNoYes
Need a Umsatzsteuer-IDNoYes
Invoice disclaimer requiredYes, §19 UStGNo
Annual revenue ceiling€25,000 (prior year), €100,000 (current year)None

What happens when you approach the revenue limit

Tracking your cumulative revenue through the year is your responsibility. The Finanzamt will not warn you; they will simply expect VAT returns from the following year if you exceeded the limit.

If you exceed €25,000 in a calendar year: You must switch to VAT registration from 1 January of the following year. Notify your Finanzamt in writing before the year ends. From that point, all invoices must include 19% VAT (or 7% where applicable), and you must file monthly or quarterly VAT pre-declarations (Umsatzsteuervoranmeldung).

If you exceed €100,000 in the current year: The switch is immediate, not from January. The invoice that takes you over the limit already has to include VAT, and so does every invoice after it. This is rare but can catch freelancers off guard during a strong year.

Voluntary switch: You can opt into VAT registration at any time, even if you are below the thresholds. This makes sense if you have significant business expenses with VAT (e.g. equipment, software) and want to reclaim input VAT. The downside: once you opt in voluntarily, you must stay VAT-registered for 5 years.

Kleinunternehmer and international clients

Many English-speaking freelancers in Germany work with clients outside Germany. The good news: your Kleinunternehmer status remains intact regardless of where your clients are located.

Non-EU clients (US, UK, Australia, etc.): For business clients, the service is taxed where the client is, so no German VAT applies. The same is true for most freelance services to private clients outside the EU, such as consulting, design, IT or translation. As a Kleinunternehmer you charge no German VAT in any case, so invoice the net amount.

EU business clients: Services to a business in another EU country are taxed in the client's country under reverse charge, and the client accounts for the VAT. Invoice without German VAT, show the client's VAT ID, and add a reverse charge note (“Steuerschuldnerschaft des Leistungsempfängers”). You can get your own VAT ID (USt-IdNr) from the Bundeszentralamt für Steuern as a Kleinunternehmer. It does not end your Kleinunternehmer status, and Kleinunternehmer do not have to file the Zusammenfassende Meldung (§ 18a Abs. 4 UStG). Check the client's VAT ID with the BZSt confirmation service before you invoice.

Note that revenue from international clients counts fully toward your €25,000 threshold. It is not excluded.

Common mistakes

⚠ Charging VAT when you shouldn't

If you add a VAT line to your invoice as a Kleinunternehmer, you legally owe that amount to the Finanzamt, even if your client never paid it. Remove all VAT lines entirely.

⚠ Missing the §19 disclaimer

Without the disclaimer, your invoice is technically non-compliant. Your client may reject it or request a corrected version before paying.

⚠ Exceeding the threshold without noticing

Track your cumulative revenue carefully. Once you exceed €25,000 in a year, you must switch to VAT from the following year. Exceeding €100,000 in the current year triggers an immediate switch.

⚠ Using a Umsatzsteuer-ID you don't have

Don't invent or leave a placeholder VAT ID field. Only show a VAT ID once the Bundeszentralamt für Steuern has issued you one; otherwise use your Steuernummer.

⚠ Forgetting to keep invoices

German law requires you to store all issued invoices for 8 years, accessible and unalterable. Digital PDFs are fine if you don't edit them after issuing.

Frequently asked questions

Do I need to register as a Kleinunternehmer separately?

No separate registration is needed. When you register as self-employed (via the Fragebogen zur steuerlichen Erfassung), the Finanzamt will ask if you want to apply for Kleinunternehmer status. Tick yes if you qualify.

Does Kleinunternehmer status affect my income tax?

No. §19 UStG is about VAT only. You still pay income tax (Einkommensteuer) on your profit regardless of Kleinunternehmer status. You still submit an annual Einkommensteuererklärung.

Can I invoice in English as a Kleinunternehmer?

Yes, invoices can be in English. The §19 UStG disclaimer is usually kept in German (or bilingual) to avoid any ambiguity with clients' accountants. All other fields can be in English.

What if my client refuses to pay without a VAT ID?

Some large corporate clients have invoicing systems that require a VAT number. If this becomes a recurring issue with EU clients, apply for a Umsatzsteuer-ID at the Bundeszentralamt für Steuern. Kleinunternehmer can get one without giving up their status, and it lets you invoice EU business clients under reverse charge.

Can I still deduct business expenses as a Kleinunternehmer?

Yes, for income tax purposes. You deduct your business expenses (equipment, software, home office portion, etc.) to calculate your taxable profit. However, you cannot reclaim the VAT portion of those expenses; that benefit is only available to VAT-registered businesses.

How long do I keep invoices?

German law requires you to keep all invoices for 8 years (§ 14b UStG, since 2025; it was 10 years before). Digital copies are acceptable if they are unalterable and retrievable.

Writing your first one? Here is how to create a German invoice in English, with a sample invoice and the English and German labels.

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