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E-Invoice Mandate: These Exceptions Apply
Small amount invoices, travel tickets, B2C, small business operators: which exceptions to the e-invoice mandate apply and what you still need to observe.
The B2B e-invoice mandate has clearly defined exceptions: small amount invoices up to 250 euros, travel tickets, invoices to end consumers (B2C), and invoices for certain tax-exempt turnover do not need to be issued as structured e-invoices. Additionally, small business operators are currently exempt from the issuance requirement – though the receiving requirement remains unaffected.
The Most Important Exceptions at a Glance
- Small amount invoices up to 250 euros: such as fuel receipts or office supplies – paper or PDF remains sufficient.
- Travel tickets: tickets in passenger transport are exempt.
- B2C transactions: invoices to private individuals are not subject to the mandate, since it applies only between domestic businesses.
- Certain tax-exempt turnover: for individual services that are tax-exempt under the turnover tax act, no e-invoice mandate applies.
- Small business operators: exempt from the issuance requirement, but not from receiving – details in the article E-Invoices for Small Business Operators.
In addition, transition periods are running during which otherwise affected businesses may still issue paper or PDF invoices. According to the status published by the Federal Ministry of Finance in March 2026, services provided to non-business legal entities and certain real estate-related services to end consumers also remain exempt. You should clarify the precise boundaries of individual cases with your tax advisor.
The Most Common Misconception: Exception Does Not Mean “Irrelevant”
An exception from the e-invoice mandate is not an exception from other obligations. Three things continue to apply:
- Storage: Even a small amount invoice is a business document and must be stored for the statutory period.
- Order and accessibility: Documents must be filed in order and in a manner that is traceable for an audit.
- Receiving: Even if you do not have to issue e-invoices – if you receive them, you must accept them and preserve them in their structured original form.
In practice, this creates a mixed document inventory: XInvoices from the wholesaler, PDF invoices from the transition period, paper receipts from the gas station. This very mix is what makes unified digital filing valuable.
Mixed Documents, One Archive
Rather than maintaining a separate process for each document type, it is better to bring everything together in one place. With webRichtung documents, documents arrive via browser upload, email import, or batch processing in the same archive. AI-powered evaluation makes the documents searchable, and archive search keeps the mixed inventory accessible.
Your filing process can support the same workflow regardless of whether a document falls under the e-invoice mandate or an exception. Which legal requirements apply in the individual case remains unaffected.
Quick Check: Are You Affected?
Four questions you can ask yourself in sequence:
- Do you sell to businesses within the country? If no (B2C only), you are not subject to the issuance requirement.
- Are you a small business operator under § 19 UStG? Then you are relieved of the issuance requirement.
- Do you issue invoices over 250 euros? Small amounts below this remain exempt.
- Do you receive invoices from businesses? Then the receiving requirement applies – regardless of all previous answers.
If in doubt, your tax advisor can help you classify your specific situation.
This article provides general information and does not replace legal or tax advice.
Frequently asked questions
Which invoices are exempt from the e-invoice mandate?
Exempt are, among others, small amount invoices up to 250 euros, travel tickets, invoices to end consumers (B2C), and invoices for certain tax-exempt turnover.
Does the e-invoice mandate apply to invoices to private customers?
No. The mandate applies to transactions between domestic businesses (B2B). You may continue to issue paper or PDF invoices to end consumers.
Are small business operators an exception?
Partially: small business operators under § 19 UStG are currently exempt from the issuance requirement, but must be able to receive e-invoices.
What applies to small amount invoices up to 250 euros?
They may continue to be issued as paper or simple PDF invoices. As a recipient, you must keep them filed in order like other documents.
Does an exception release you from the storage requirement?
No. Invoices exempt from the mandate remain documents subject to retention and must be kept in order and unchanged for the statutory periods.