Non-VAT payer and e-invoicing 2027: what you must do and what you do not have to do
A non-VAT payer does not have to issue e-invoices, but from 1. 1. 2027 must be able to receive them. We also explain it for sole traders registered under § 7a and landlords.
There are many inaccuracies circulating around e-invoicing. The most common question from sole traders is: “I’m not a VAT payer, does this affect me at all?” Yes, but only partly.
You do not have to issue e-invoices
The obligation to prepare invoices in electronic format from 1/1/2027 applies only to VAT payers registered under § 4, § 4b or § 4c of the VAT Act. The Financial Administration states this explicitly in its answers: the obligation does not apply to a taxable person who is not a VAT payer.
You can therefore continue issuing invoices as before, for example in PDF format.
However, you must be able to receive them
From 1/1/2027, every legal entity and every business owner must be able to receive an e-invoice if a VAT payer is required to send it to them. This applies to:
- sole traders and liberal professions (lawyer, architect, artist, etc.),
- self-employed farmers,
- property landlords,
- limited liability companies, joint-stock companies, non-profit organisations and public institutions.
In practice, this means having a contract with a digital postman through whom your e-invoices will arrive. If you buy from VAT payers (materials, telephone services, software, energy), your invoices will now arrive this way.
Registration under § 7a does not make you a VAT payer
If you registered under § 7a (for example because of advertising on Facebook or services for EU businesses), you have a VAT number, but you are not a VAT payer. For e-invoicing, the same applies as for other non-payers: you do not have to issue them, but you must be able to receive them. More in the article Registration under § 7a.
Be careful with your VAT number if you join voluntarily
A non-payer may join e-invoicing voluntarily. This does not create an obligation to send all invoices this way. Two practical notes:
- According to the Financial Administration, the system reports data from an invoice when the issuer’s or recipient’s VAT number appears on it. It does not assess whether the e-invoice was mandatory.
- Under the Peppol rules (BR-O-02), for an invoice issued by a non-payer (VAT category “O”, outside the scope of tax), the supplier’s or customer’s VAT number must not be stated. The Tax ID number is stated instead.
DSDATA handle this automatically. For a non-payer, the VAT number is not included in the e-invoice, even if it has been assigned to you under § 7a.
What if you become a VAT payer during the year
If you exceed turnover of 50 000 €, you become a VAT payer from 1 January of the following year. If you exceed 62 500 €, you become a VAT payer immediately. From that moment, the e-invoicing obligations also apply. We explain how the thresholds work in the article When you become a VAT payer.
Summary
| Non-payer (including § 7a) | VAT payer | |
|---|---|---|
| Issue e-invoices | no (voluntarily, yes) | yes, domestic B2B/B2G |
| Receive e-invoices | yes | yes |
| Digital postman | yes, for receipt | yes |
Sources
This article is for information purposes only and is based on the regulations and sources listed in the text as valid on the verification date. It does not replace tax advice – for a specific situation, please contact a tax adviser or the Financial Administration.
Invoices that comply with the law – automatically
The correct VAT regime, mandatory details, PAY by square QR payment and e-invoicing for 2027. Free for 5 documents per month.
Try for free