E-invoicing for B2C in Germany: does the mandate apply to online shops?

There is no e-invoicing mandate for sales to private individuals. The mandate only covers supplies to another business for its business when both parties are established in Germany (§ 14(2) sentence 2 no. 1 UStG, German). You may keep sending invoices to consumers on paper, or as a PDF or e-invoice with the customer's consent (§ 14(1) sentence 5 UStG, German).

For online shops the honest answer is more complicated, and that is why "we only sell B2C" is a risky assumption.

The problem: hidden B2B in an ordinary checkout

Your shop does not decide whether an order is B2B. The buyer does. When a GmbH (a German limited company) orders coffee for the office through your regular checkout, that is a supply to a business for its business, even without a business customer program, without a VAT ID in the form and without you noticing. In your system these orders look like any consumer order.

From 2027 (for businesses with more than €800,000 in total turnover in the prior year) or 2028 (for everyone), exactly these invoices must be issued as structured e-invoices (§ 27(38) UStG, German). The tax authorities leave some room: they will not object to a breach as long as you did not know, and could not have recognized with the care of a prudent businessperson, that a business was ordering for its business. A VAT ID entered at checkout can be an indication (section 14.1(6) UStAE, German). A shop that sends every invoice as a plain PDF is therefore out of compliance at the latest in every recognizable B2B case, and the line between recognizable and not recognizable is blurry in individual cases.

The practical fix: one format for everyone

For complete standard invoices, the ZUGFeRD hybrid is the simplest common path: consumers see a familiar PDF invoice, and business customers also get the machine-readable data. If a domestic small-amount invoice lacks the recipient's address, Rechnungskit checks the separate § 33 path for small-amount invoices instead (Kleinbetragsrechnung). That exception only applies up to a total of €250 and never to sales under § 3c, § 6a or § 13b UStG (§ 33 sentences 1 and 3 UStDV, German).

That is how Rechnungskit works: one standard for every invoice, whoever places the order.

What else is exempt

Besides B2C, there are further exceptions from the obligation to issue e-invoices: small-amount invoices up to €250 (§ 33 sentence 4 UStDV, German), tickets for passenger transport (§ 34(1) sentence 2 UStDV, German), sales that are tax-exempt under § 4 nos. 8 to 29 UStG and therefore trigger no invoicing obligation at all (§ 14(2) sentence 2 UStG, German), and invoices from small businesses under § 19 UStG (Kleinunternehmer, the German small business scheme), which may always be sent as an "other invoice" (sonstige Rechnung, meaning paper or a plain PDF) (§ 34a sentence 4 UStDV, German).