Registration of electronic cash register systems

Companies that work with electronic cash register systems must register them with the tax office. There is still a transitional period until July 2025.

Background

The reporting obligation for electronic recording systems (“elektronische Aufzeichnungssysteme“, eAS), which has actually been in place since 2020, has been repeatedly postponed due to technical difficulties. A procedure for reporting electronic cash register systems has now been available since the beginning of 2025.

The registrations are intended to provide the tax authorities with an overview of the eAS in use and information on which systems are used, their age, their possible networking and the technical security equipment (“technische Sicherheitseinrichtung”, TSE) that has been mandatory since 2023. The declared aim is to curb tax evasion in cash transactions and to ensure a complete and unalterable record of all cash transactions.

In the decree from the Federal Ministry of Finance (“Bundesfinanzministerium, BMF”) dated June 24, 2024, the tax authorities commented on numerous points and created exemptions and transitional regulations.

To whom does the reporting obligation apply?

The reporting obligation applies in principle to all companies, including small companies, that use eAS with TSE. This includes in particular

Electronic or computerized cash register systems or cash registers
Software-based eAS (apps) on tablets, smartphones, online applications, etc.
EC terminals with connected online checkout software
Merchandise management/ERP/billing systems with a cash register module or cash book
Scales with cash register function
EU taximeter
Odometers

Temporary exceptions exist under certain conditions only for taximeters without TSE.

Notice:
Rented or leased cash register systems are also subject to the register obligation, as these are treated in the same way as purchased systems

The register itself can also be carried out by commissioned third parties, e.g. tax consultants, cash register service providers or cash register (software) manufacturers.

What information must be provided?

The following information must be provided:

Name of the taxable person
Tax number of the taxable person
Type and number of eAS used
Type of certified TSE
Serial number of the cash register
Date of acquisition and commissioning or decommissioning

If there are several permanent establishments, all existing eAS must be assigned to one permanent establishment. At the same time, all eAS of the respective business premises must be recorded and registered with each notification. Even in the case of multiple or different uses, an eAS must be clearly assigned to a specific business premises, usually the one in which it is predominantly used. A change of business premises must also be reported.

If several cash registers are combined in a network system, each individual device must still be reported to the tax office. If, on the other hand, individual eAS do not have a cash register function (e.g. for order devices in the catering trade), only the system with a cash register function needs to be registered.

To whom and how should the cash register information be transmit?

The report is made to the responsible tax office and exclusively electronically via “Mein Elster”, the ERiC interface, alternatively an XML file can be uploaded. Reporting via paper forms, PDF forms or similar is not possible.

However, manual entry via the “Mein Elster” online application should only be used in exceptional cases, as this is time-consuming and error-prone due to the large amount of data involved.
In some cases, eAS providers also allow the report to be transmitted directly from the cash register software or the corresponding online application via the so-called ERiC interface of the tax authorities. This is usually the case with cloud TSE providers. An XML file can often be generated accordingly, which is then uploaded to the tax authorities.

A DATEV solution is also expected to be available for registration from April 2025. As a cloud application, “DATEV-Kassenmeldung” - similar to “DATEV-Kassenarchiv online” - will be made available via the “MeinFiskal” platform.

Deadlines and transitional regulations for the notification

The respective notification must generally be submitted within one month of commissioning or decommissioning the eAS. However, the decree of the BMF dated June 24, 2024 grants a transitional period: eAS acquired before July 01, 2025 must be registered by July 31, 2025 at the latest. In the event of a later acquisition, the notification must be received by the tax office within one month.

A notification of decommissioning must only be submitted if the commissioning has already been reported at this time.

Failure to comply with the register obligation is an administrative offense under Section 379 (1) AO and can be punished with a fine. The exact amount of the fine may vary depending on the severity of the violation.

Practical tips
In order for companies to meet their register obligations on time, they should promptly obtain an overview of the devices used in their company. In addition, the respective systems and the possible registration options should be checked.

If the data intended for transmission is not automatically provided by the systems used, the necessary information should also be compiled in good time. The scope of the data to be transmitted has increased considerably compared to the scope originally envisaged by the legislator. For example, information on the “acquisition of the eAS” and the “commissioning of the eAS” must be provided. The corresponding dates are unlikely to be identical in most cases. In addition to the information on the eAS, numerous details on the TSE must also be provided. The effort involved should therefore not be underestimated.

Our consulting services
We support you in compiling the required data, checking it, submitting it and providing the necessary documentation. For example, the registration of the eAS is part of the procedural documentation for cash management.

If necessary, we can draw on information and documents already available to us.

If automatic transmission from your systems is not possible, we can do this via our systems - in particular DATEV, as soon as it is available