- Short answer
- Yes: a German Kleinunternehmer is still an Unternehmer, so UStG §14b requires keeping invoices issued and received for 8 years.
- Who §14b binds
- Every Unternehmer; §2 UStG has no turnover test, and §19 does not list §14b among the rules it switches off.
- When the clock starts
- End of the calendar year of issue; AO's 8-year wording applies from 1 January 2025.
- What to keep
- A copy of every invoice you issue, including paper or PDF invoices, and every invoice you receive, e-invoices included.
- What Shopify says
- Shopify help pages we read are silent on retention for Kleinunternehmer.
Does UStG §14b apply to a Kleinunternehmer?
UStG §14b (1) puts the duty to keep invoices on "der Unternehmer", and UStG §2 defines one as anyone carrying out a commercial or professional activity independently, with no turnover test.
UStG §19 (1) makes a Kleinunternehmer's turnover tax-exempt and switches off four sets of rules:
- intra-Community supply exemptions (§4 Nr. 1b, §6a)
- waiving exemptions (§9)
- VAT IDs on invoices (parts of §14a)
- filing duties (§18 (1) to (4))
§14b is not on that list, and none of the law pages we read on October 4, 2026 (§§2, 14, 14b and 19 UStG, §34a UStDV) exempts a Kleinunternehmer from it.
In its e-invoice FAQ, the finance ministry (BMF) names Kleinunternehmer among Unternehmer:
Darunter fallen z. B. auch Freiberufler oder Personen, die selbst ausschließlich steuerfreie Umsätze erbringen, wie etwa Vermieter von Wohnungen, Kleinunternehmer oder Ärzte.
How is the 8-year period counted?
The 8 years (Aufbewahrungsfrist) run from the end of the calendar year the invoice was issued. AO §147 sets the same 8 years for accounting vouchers from 1 January 2025, covering documents whose old period had not expired by 31 December 2024 (EGAO Art. 97 §19a).
Other AO document classes carry 10 or 6 years; see how many years German law makes you keep store records.
Which Shopify invoices does a Kleinunternehmer keep?
Keep a copy of every invoice (Rechnung) you issue, including the "sonstige Rechnung" (paper, or PDF if the recipient agrees) that UStDV §34a always permits for Kleinunternehmer, and every invoice you receive, e-invoices included.
The BMF says Kleinunternehmer need not issue e-invoices but must be able to receive them.
On Shopify's side, none of the billing, EU tax and German Shopify Payments help pages we read on October 4, 2026 addresses retention for Kleinunternehmer. For audit exports, see what the Data Exporter app gives you for GoBD.
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