Knowledge · documents

E-Invoicing Obligation: These Are the Exceptions

Small-amount invoices, transport tickets, B2C, small businesses: Which exceptions to the e-invoicing obligation apply and what you still need to keep in mind.

The e-invoicing obligation in B2B has clearly defined exceptions: small-amount invoices up to 250 euros, transport tickets, invoices to end consumers (B2C), as well as invoices for certain tax-exempt transactions do not have to be issued as a structured e-invoice. In addition, small businesses are exempt from the issuing obligation under current law – the obligation to receive remains unaffected.

The most important exceptions at a glance

Small-amount invoices up to 250 euros: for example fuel receipts or office supplies – here paper or PDF is still sufficient.
Transport tickets: tickets in passenger transport are exempt.
B2C transactions: invoices to private individuals are not subject to the obligation, as it only applies between domestic businesses.
Certain tax-exempt transactions: for individual services that are tax-exempt under the Value Added Tax Act, there is no e-invoicing obligation.
Small businesses: exempt from the issuing obligation, but not from receiving – details in the article E-Invoicing for Small Businesses.

In addition, transition periods are running during which otherwise affected businesses may still issue paper or PDF invoices. You should clarify the exact classification of individual cases with your tax advisor, as the authorities have specified the rules several times since 2024.

The most common misconception: an exception does not mean "it doesn't matter"

An exception to the e-invoicing obligation is not an exception to the other obligations. Three things still apply:

Retention: Even a small-amount invoice is an accounting document and must be retained for the statutory period.
Order and findability: Documents must be filed in an orderly manner and traceable for an audit.
Receipt: Even if you do not have to issue e-invoices – if you receive any, you must accept them and secure them in the structured original.

In practice, this results in a mixed set of documents: XRechnungen from the wholesaler, PDF invoices from the transition period, paper receipts from refueling. It is precisely this mix that makes a uniform digital filing valuable.

Mixed documents, one archive

Instead of maintaining a separate process for each type of document, it is better to bring everything together in one place. With webRichtung documents, documents enter the system via whichever route fits at the moment: by browser upload, directly from the scanner (WebDAV), via SFTP, or automatically from your invoice mailbox. Each document is read and classified so that you can later find it by content, type, date, or amount – and retain it unalterably in the GoBD archive with Object Lock for 6, 8, or 10 years.

This way, it no longer matters for your filing whether a document falls under the e-invoicing obligation or under an exception: the process is the same, and so is the verifiability.

Quick check: Are you affected?

Four questions you can ask yourself one after the other:

Do you sell to businesses in the domestic market? If not (only B2C), you are not covered by the issuing obligation.
Are you a small business under § 19 UStG? Then you are relieved when it comes to issuing.
Do you issue invoices over 250 euros? Smaller amounts below that remain exempt.
Do you receive invoices from businesses? Then the obligation to receive applies – regardless of all previous answers.

When in doubt, your tax advisor can help with classifying your specific case.

This article provides general information and does not replace legal or tax advice.

FAQ

Which invoices are exempt from the e-invoicing obligation?

Exempt are, among others, small-amount invoices up to 250 euros, transport tickets, invoices to end consumers (B2C), as well as invoices for certain tax-exempt transactions.

Does the e-invoicing obligation apply to invoices to private customers?

No. The obligation concerns transactions between domestic businesses (B2B). To end consumers, you may still issue paper or PDF invoices.

Are small businesses an exception?

Partly: Small businesses under § 19 UStG are exempt from the issuing obligation under current law, but must be able to receive e-invoices.

What applies to small-amount invoices up to 250 euros?

They may still be issued as paper or simple PDF invoices. As the recipient, you must keep them in an orderly manner like other documents.

Does an exception release you from the retention obligation?

No. Even exempt invoices remain documents subject to retention and must be retained in an orderly and unaltered manner over the statutory periods.

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