Your type of register makes the difference.
A manual cash box and an electronic cash-register system have different requirements. The proposed cash-register obligation from 2028 is a separate question. It does not yet change the law currently in force.
You use a manual cash box.
You can continue to use a cash box or drawer without electronic recording. As a general rule, transactions must be recorded individually and in an orderly manner; cash income and expenditure must be recorded daily. Discuss with your tax adviser whether an exemption from individual recording applies and which documents your business needs.
The receipt-issuing duty under § 146a(2) AO applies to the electronic recording systems covered by that provision. This does not imply a blanket exemption from other receipt or record-keeping duties.
Sources: BMF: questions on the Cash Register Act, § 146 AO.
You use an electronic register.
For an electronic cash-register system covered by the law, the following points are particularly relevant together. A recent device alone does not tell you whether all processes are properly set up.
| Area | What you should check |
|---|---|
| TSE | The certified technical security device protects digital records against undetected changes. Ask your provider to show you which TSE your system uses and how its operation is monitored. |
| Receipts | For transactions within scope, the receipt must be issued and made available in immediate connection with the transaction. It may be provided on paper or, with the recipient's consent, electronically in a standardised data format. Other legal requirements remain unaffected. |
| Records | Transactions must be recorded in a traceable manner. Document with your provider how to access data and exports. |
| Register notification | For electronic recording systems subject to notification, the general deadline is one month after acquisition or decommissioning. Check existing notifications and outstanding deadlines now. Have the serial number, TSE details and acquisition or decommissioning date ready, among other information. |
Legal basis: § 146a AO, § 1 KassenSichV and § 6 KassenSichV. This assessment assumes that your particular system falls within the scope of the rules.
Rented or leased systems must be treated like acquired systems for notification purposes if they fall within the notification requirement. Clarify the relevant start date and any later decommissioning for your situation.
Cash-register notifications are submitted for each business establishment and must include all of its electronic recording systems. The official ELSTER form contains procedural guidance. Special and transitional rules must be assessed for the individual case.
Three misunderstandings that are easy to avoid.
“We only accept cards, so the TSE rules do not apply to us.”
The payment method alone does not support that conclusion. The electronic recording system you use and its functions also matter. Have the particular system assessed.
“My register is already electronic. I will definitely need a new one in 2028.”
The planned introduction of a cash-register obligation does not imply a general replacement requirement for systems that are already suitable. Check your existing equipment and the current requirements first.
“The TSE also takes care of my notification.”
Technical protection and notification to the tax office are separate tasks. Explicitly clarify who submits the notification and where the evidence is kept.
Practical things you can prepare now.
- Create an equipment list. Which registers, apps and connected payment systems do you use at which locations?
- Gather your documents. Keep the provider, model, serial number, TSE documents, acquisition date and existing notifications together where you can find them.
- Review your processes. Ask for a demonstration of receipt provision, cancellations and data export on your own register.
- Assign the open questions. Technical questions go to the provider. Discuss tax classification and individual duties with your tax adviser.
Start by clarifying your situation.
The Cash Register Check asks a few questions and creates a relevant preparation checklist. You do not need exact turnover figures or an email address.
Go to the Cash Register Check