The **KassenSichV officially came into force** on 1.1.2020. So far, the picture of the intensity with which cash register manufacturers have dealt with the topic is varied. However, this will change abruptly on 1.10.2020. From this date, every cash register must be equipped with a TSS (basic information on this can be found [here](/en/articles/necessary-documents-for-cash-audit)).As a cash register manufacturer, the question arises: Which TSS solution do I use? Compliance with the law is often the decisive criterion. 

The problem:

**No TSS is currently fully certified - only provisionally approved!**

#### So what can cash register manufacturers do? 

TSS customers basically have the option of integrating cloud TSSs or hardware TSSs. There are huge differences in terms of certification, performance spectrum, practicability and costs. We would like to go into this in more detail below.

#### The current situation

Some hardware TSS providers have a temporary approval for their systems and therefore have to re-certify by the end of 2020 at the latest. However, there are major risks in doing so - for example, by upgrading to a new protection profile. TSSs with a temporary release are de facto only partially tested and thus there is a risk that no final certification will take place. This would create several problems:

* The TSS manufacturer must undergo re-certification at the end of 2020. If the re-certification is not completed positively, a new TSS solution must be found.  In the worst case, customers would have to look for a new provider.
* If the re-certification should reveal gross deficiencies in the TSS, there could be a complete ban on operations despite the current provisional approval. This would mean that all TSSs already in operation would have to be replaced.

#### What are the consequences?

Possibly, there would have to be a complete replacement of all HW TSSs. Hardware solutions are very costly to purchase and present enormous logistical challenges. So if changes were ever made, all hardware TSSs would potentially have to be completely replaced. This would lead to repeated costs and roll-out challenges. Furthermore, hardware TSSs cannot keep up with the performance spectrum of cloud solutions around the necessary processes.

The certification of a cloud TSS is only a matter of time. There are POS systems where it is technically impossible to install a hardware component (e.g. based on RDP - Remote Desktop Protocol). TSSs as a **Cloud solution are also officially confirmed** by the BSI (see [FAQ BSI](https://www.bsi.bund.de/DE/Themen/Unternehmen-und-Organisationen/Standards-und-Zertifizierung/Schutz-vor-Manipulation-an-digitalen-Grundaufzeichnungen/Veroeffentlichungen/veroeffentlichungen_node.html)). The leading provider of cloud TSSs is fiskaly, due to its technological edge, as well as its unique range of services. "The beauty of a cloud solution is simplicity coupled with infinite possibilities," documents Dr. Patrick Gaubatz, TSS expert at fiskaly.

**Our recommendation is quite clear: a cloud TSS with which all (legal) requirements can be responded to quickly and cheaply.** As well as, for example, to a repeated postponement of the non-objection rule. If there are ever legal changes or other updates, you can integrate them once centrally with a cloud solution and the issue is taken care of. With a hardware solution, you literally have to take each POS in hand individually. 

The **Cloud solution from fiskaly** goes far beyond the actual signature unit! While hardware is purely the signature unit, the cloud solution from fiskaly offers innovative added value for customers (eBeleg, fiskaly DSFinV-K, dashboard for managing all TSSs, activation at the tax office, SSO, multi-client capability, ...) and is also more cost-effective - contact fiskaly at **sales@fiskaly.com.**

TSS customers basically have the option of integrating cloud TSSs or hardware TSSs. There are huge differences in terms of certification, performance spectrum, practicability and costs.

Everything about certification and TSS

alles-rund-ums-thema-zertifizierung-und-tse

Digitalisierung ist von Politik und Marktteilnehmern in Deutschland gefordert und somit auch eine Möglichkeit die [Kassensicherungsverordnung](https://kassensichv.net/kassensicherungsverordnung) technologieoffen umzusetzen. In diesem Artikel wird die Systemarchitektur der [cloudbasierten TSE](https://kassensichv.net/cloud-tse) fiskaly SIGN DE beschrieben. Wir gehen auf die Komponenten und deren Funktionen ein und stellen [fiskaly SIGN DE](https://www.fiskaly.com/de/signde) im gesetzlichen Kontext dar.

## Aufbau fiskaly SIGN DE Architektur

Die fiskaly SIGN DE Architektur ist stark durch die gesetzlichen Anforderungen an eine zertifizierte [Technische Sicherheitseinrichtung (TSE)](https://kassensichv.net/cloud-tse) sowie die Umsetzung moderner, verteilter Systeme geprägt. Die Cloud-TSE fiskaly SIGN DE besteht aus zertifizierten Komponenten und weitere Komponenten, die bestimmte Sicherheitsanforderungen erfüllen, um einen manipulationssicheren Betrieb zu gewährleisten. Die Richtlinien werden durch das [Bundesamt für Sicherheit in der Informationstechnik](https://www.bsi.bund.de/) (BSI) vorgegeben. fiskaly SIGN DE ist ein verteiltes System und wurde auf Basis der spezifischen Vorgaben für derartige Systeme [durch das BSI zertifiziert](https://www.fiskaly.com/de/zertifikate-verbaende).

## Wie ist fiskaly SIGN DE aufgebaut

Die zertifizierten Komponenten, SMAERS (Security Module Application for Electronic Record-keeping Systems) und CSP-L (Crypto Service Provider Light), stellen die Kernfunktionalität von fiskaly SIGN DE, die Fiskalisierung, bereit und sind im Zusammenspiel die zertifizierte Cloud-TSE.

Sowohl SMAERS als auch CSP-L werden von fiskaly als Teil des Produktes [fiskaly SIGN DE](https://www.fiskaly.com/de/signde) verwaltet. Alle fiskaly SMAERS und CSP-L Instanzen sowie relevante Ressourcen werden in Rechenzentren auf deutschem Bundesgebiet gehostet und sind durch technische, physische und organisatorische Maßnahmen vor dem Zugriff unberechtigter Dritter geschützt.

Um die sichere und konforme Interaktion zwischen den Komponenten der fiskaly Cloud-TSE sowie der verschiedenen Kassensysteme zu ermöglichen, sind weitere Komponenten notwendig. Sie regeln Funktionalitäten wie Zugangskontrolle, Eingabevalidierung und Dienstintegration. So können die Anforderungen an den Umgebungsschutz garantiert erfüllt, der zertifizierte Betrieb der TSE gewährleistet und ein sehr hohes Schutzniveau erreicht werden.

![](/img/architektur-sign-de-graphik-klein.webp)

## Die zertifizierten Komponenten der fiskaly Cloud-TSE

* fiskaly SIGN Cloud-TSE als Gesamtsystem ([TR-03151](https://www.bsi.bund.de/DE/Themen/Unternehmen-und-Organisationen/Standards-und-Zertifizierung/Technische-Richtlinien/TR-nach-Thema-sortiert/tr03151/tr03151_node.html) und [TR-03153](https://www.bsi.bund.de/DE/Themen/Unternehmen-und-Organisationen/Standards-und-Zertifizierung/Technische-Richtlinien/TR-nach-Thema-sortiert/tr03153/tr-03153.html))
* Crypto Service Provider Light ([CSP-L](https://www.bsi.bund.de/SharedDocs/Zertifikate_CC/CC/Serveranwendungen_Sonstiges/1153_1153V2_1153V3.html))
* Security Module Application for Electronic Record-keeping Systems ([SMAERS](https://www.bsi.bund.de/SharedDocs/Zertifikate_CC/CC/Fiskalisierung/1130_1130V2.html))

## SIGN DE Komponenten in der TSE-Umgebung

Die folgenden Komponenten in der TSE-Umgebung gewährleisten die Sicherheitsanforderungen:

* fiskaly SIGN DE Middleware als Teil des ERS
* fiskaly SMAERS Gateway
* fiskaly SIGN DE Backend Komponenten
* weitere Komponenten

Detaillierte Beschreibungen der Komponenten und deren Funktionalitäten finden Sie im nächsten Abschnitt.

## Die zertifizierten Komponenten von SIGN DE

Folgende Komponenten von fiskaly SIGN DE wurden durch das BSI zertifiziert. Die Zertifizierungsdokumente sind zum [Download](https://www.fiskaly.com/de/zertifikate-verbaende) verfügbar.

![](/img/systemarchitektur-sign-de-1.webp)

## Zertifizierter Betrieb von fiskaly SIGN DE

Registrierkassen erfüllen zwei Aufgaben:

* eine geschäftliche Transaktion aufzeichnen und
* einen Beleg erstellen, der diese Transaktion bestätigt

In der Praxis sind die von einem Unternehmen betriebenen Registrierkassen Teil eines größeren, verteilten Systems, das im offiziellen Amtsgebrauch als “elektronisches Aufzeichnungssystem” (englisch: Electronic Record-keeping System - ERS) bezeichnet wird. Die Registrierkasse - das Gerät selbst - ist lediglich der sichtbare, kundennahe Endpunkt eines ERS.

Die Funktionalität des ERS wird durch eine umfangreiche Reihe verteilter Backend-Funktionen gegeben, darunter Finanz- und Authentifizierungsdienste sowie Archivierung. Jede dieser Funktionen kann von verschiedenen Anbietern abgedeckt werden. Aus Sicht des Kassennutzers sind diese in einem einzigen ERS integriert. Darüber hinaus ist ein ERS ein Managementsystem, das mehrere Registrierkassen pro Filiale, pro Kunde, pro Organisation usw. integriert und zusätzliche Funktionen wie beispielsweise Datenabruf und -analyse bereitstellen kann.

![](/img/systemarchitektur-sign-de-3.webp)

## Definition ERS

Der Gesetzgeber, das [Bundesministerium für Finanzen](https://www.bundesfinanzministerium.de/) (BMF), definiert die in der Praxis sehr unterschiedlichen Umsetzungen von Kassensystemen und Architekturen wie folgt:

>  **Ein elektronisches Aufzeichnungssystem ist die zur elektronischen Datenverarbeitung eingesetzte Hardware und Software, die elektronische Aufzeichnungen zur Dokumentation von Geschäftsvorfällen und somit Grundaufzeichnungen erstellt.**

(Anwendungserlass zur Abgabenordnung (AEAO) zu § 146 Nr. 2.1.4)

Diese Definition wird in offiziellen BSI Dokumenten referenziert und wurde in einer individuellen Anfrage von fiskaly am 21.04.2022 durch das BMF nochmals bestätigt. Sie ist bewusst breit gefasst, um Technologieoffenheit zu ermöglichen und die notwendige Digitalisierung zu unterstützen.

## fiskaly SIGN DE als Teil des ERS

fiskaly SIGN DE ist für internetfähige Kassensysteme konzipiert und macht jedes Kassensystem zu einem verteilten Aufzeichnungssystem. Anstelle einer Hardware-basierten TSE-Lösung, die eine Integration und Wartung vor Ort in jedem Gerät, in jeder Filiale erfordern würde, ist fiskaly SIGN DE eine echte Cloud-TSE, also ein reiner Software-Online-Service. fiskaly SIGN DE wird einfach und transparent als eine weitere Komponente in ERS-Systeme integriert. Die fiskaly Komponente im ERS stellt die Fiskalisierungsanforderung sowie Funktionen für die erleichterte Verwaltung von fiskalisierungsbezogenen ERS-Daten sicher. Somit sind Komponenten von fiskaly SIGN DE ein essentieller Bestandteil des Aufzeichnungssystems.

## Umgebungsschutz SIGN DE

Die Umgebung der Komponenten der fiskaly SIGN DE ist so konfiguriert und beschaffen, dass die Komponenten physisch, organisatorisch und technisch geschützt sind. Im Umgebungsschutzkonzept (USK) beschreibt der TSE-Hersteller, wie der Umgebungsschutz zu gewährleisten ist. Um den Umgebungsschutz zu gewährleisten, werden, zusätzlich zu den eingebauten Sicherheitseigenschaften der Komponenten, Sicherheitsmaßnahmen bezüglich ihrer physischen und logischen Umgebungen implementiert. Organisatorische und technische Maßnahmen bieten eine zusätzliche Sicherheitsebene, indem sie die Kommunikation mit den Komponenten und den physischen Zugang zu den Komponenten durch nicht autorisierte Personen und andere Softwareprozesse einschränken und kontrollieren.

Grundsätzlich sollten Umgebungsschutzdokumente sowie weitere Zertifizierungs- oder betriebsrelevante Dokumente von Ihrem Anbieter bereitgestellt werden. Unsere Dokumente finden Sie [hier](https://developer.fiskaly.com/en/docs/certification).

![](/img/systemarchitektur-sign-de-4.webp)

Digitalisierung ist von Politik und Marktteilnehmern in Deutschland gefordert und somit auch eine Möglichkeit die Kassensicherungsverordnung technologieoffen umzusetzen. In diesem Artikel wird die Systemarchitektur der cloudbasierten TSE fiskaly SIGN DE beschrieben.

fiskaly SIGN DE

SIGN DE Komponenten in der TSE-Umgebung

## What Cash Register Providers and Retailers Need to Know

The new [draft of the Annual Tax Act 2024](https://www.bundesrat.de/drs.html?id=369-1-24), presented by the Federal Cabinet, places particular emphasis on the strict enforcement of the receipt issuance obligation and the tamper-proof nature of cash register systems. For the cash register industry and providers of technical security systems (TSS), the tightened requirements for receipt issuance and reporting obligations are of particular importance.

## Key Points at a Glance: What Does the Current Draft Mean for the Receipt Issuance Obligation and TSS Systems?

No specific innovations, such as QR codes on receipts, have been proposed. However, the draft shows that the demands for transparency and security in the cash register environment continue to increase. Cloud-based TSS solutions and digital receipts, like those offered by fiskaly, could therefore play an even more central role.

## Stricter Rules for the Receipt Issuance Obligation

Since the introduction of the [Cash Register Security Ordinance](https://kassensichv.net/en/kassensicherungsverordnung) (KassenSichV) in 2020, retailers have been required to issue a receipt for every transaction—either in [paper form](https://www.fiskaly.com/blog/paper-receipt-facts) or digital. The draft of the Annual Tax Act 2024 strengthens these requirements and now provides for stricter penalties for violations of the [receipt issuance obligation](https://kassensichv.net/en/articles/receipt-issuance-obligation-in-germany-background-effects-and-alternatives). For cash register providers, retailers, and taxpayers, this is particularly important as a properly issued receipt forms the basis for the verifiability and tamper-proof nature of transactions.

For cash register providers offering systems to their customers, it is crucial that their cash register systems implement the receipt issuance obligation reliably and efficiently. Companies that have already integrated [cloud-based TSS solutions](https://kassensichv.net/en/cloud-tss) like [fiskaly SIGN DE](https://www.fiskaly.com/signde) can flexibly handle both paper-based and [digital receipts](https://www.fiskaly.com/digital-receipt). Digital receipts not only provide security and legal compliance but also meet modern customer demands.

> Especially for high-traffic sectors, such as bakeries, we offer a solution for digital receipts that doesn't require new cash register equipment. This allows businesses to remain flexible and future-proof without having to invest in expensive hardware.

Oliver Abl, Country Manager of fiskaly Germany.

## Reporting Obligations and Technical Inspections

Another key aspect of the draft law is the tightened requirements for technical inspections and [reporting obligations for TSS systems](https://kassensichv.net/en/articles/new-reporting-obligations-2025-cash-registers-taximeters-odometers). Companies must ensure that their TSS complies with legal requirements and is properly registered with the relevant authorities. Manipulations and failures must be reported immediately to maintain legal compliance.

For you, our customers who have integrated the cloud-based TSS solution SIGN DE, there are clear advantages: The cloud solution allows for the quick and automated reporting of errors and manipulation attempts. This significantly simplifies the entire reporting process and increases responsiveness to potential compliance incidents—ensuring that you and your customers remain compliant while reducing administrative overhead.

## 2024 Brings More Security for Cash Register Systems

The draft of the Annual Tax Act 2024 makes it clear that the requirements for transparency, security, and compliance are continuing to increase. Companies already relying on cloud-based TSS solutions like those from fiskaly benefit from a future-proof technology that meets both current and future legal requirements.

> It is good that the security and clarity in the inspection process are being strengthened. This creates equal conditions for all taxable companies, contributing to fairness and transparency.

Oliver Abl, Country Manager of fiskaly Germany

Although no specific innovations, such as QR codes on receipts, are included, the investment in modern, flexible TSS solutions remains essential to stay compliant with the law. Cloud TSS allows for quick adaptation to changes and ensures efficient compliance.

### Conclusion: Cloud-Based TSS Solutions Are the Future-Proof Choice

#### Additional Information

For more detailed information on the Annual Tax Act 2024 and the changes it contains, you can view the full [draft of the Annual Tax Act 2024](https://www.bundesrat.de/drs.html?id=369-1-24) here.

The Annual Tax Act 2024 introduces stricter regulations for receipt issuance and cash register security. Learn how cash register providers and retailers can meet these new requirements with modern TSS solutions like cloud-based systems.

The Annual Tax Act 2024 tightens regulations on receipt issuance and cash register security. Learn how cloud-based TSS solutions help retailers and providers stay compliant.

Annual Tax Act 2024: New Requirements for Cash Register Security and Receipt Obligation

Annual Tax Act 2024 Strengthens Cash Register Security

Starting January 1, 2025, new regulations for the reporting of electronic recording systems will come into effect. These apply to both cash registers and EU taximeters and odometers. Here are the key details and deadlines businesses need to know.

## What Changes in 2025?

From the new year, all electronic recording systems must be reported to the tax office. This regulation aims to enhance transparency and traceability in the use of such systems and to prevent tax evasion**.**

## Important Deadlines

### Cash Registers:

* **Systems acquired before July 1, 2025,** must be reported by July 31, 2025.
* **Systems acquired from July 1, 2025**, onwards must be reported within one month of acquisition.
* Similarly, **systems taken out of operation from July 1, 2025**, must be reported within one month of decommissioning.

### EU Taximeters and Odometers:

* These must also be reported from January 1, 2025, once they are equipped with a certified technical security device (TSS).
* Systems acquired or equipped with a TSE before July 1, 2025, must be reported by July 31, 2025.
* Systems acquired or equipped with a TSE from July 1, 2025, must be reported within one month of acquisition or equipment.

## Special Cases for Decommissioning

Before reporting the decommissioning of a system, its acquisition must have already been reported. Systems that were permanently decommissioned before July 1, 2025, and are no longer in operation, only need to be reported if their acquisition was previously reported.

## Electronic Submission

Reports should be submitted via the "Mein ELSTER" program and the ERiC interface. This electronic submission option will be available from January 1, 2025, and is intended to simplify the process for businesses.

### Electronic Submission via fiskaly SIGN DE x Submission API

The fiskaly SIGN DE x Submission API offers a user-friendly solution for electronically submitting cash register reports. This API enables businesses to quickly and efficiently register their cash registers with the tax authorities, ensuring compliance with the new legal requirements.

## Repeal of Previous Regulations

With the new regulations coming into force, the BMF decree dated November 6, 2019, will be fully repealed. This means all businesses must adhere to the new reporting obligations from January 1, 2025.

## Conclusion

The new reporting obligations for electronic recording systems represent a significant change that businesses should be aware of early. By timely reporting their systems, businesses can ensure they comply with the new legal requirements and avoid potential penalties. Utilize the electronic submission via [fiskaly SIGN DE Submission API](https://developer.fiskaly.com/api/sign-de/submission/v1) to make the process as smooth as possible.

**Sources:**

* [Start of the reporting obligation according to § 146a paragraph 4 Fiscal Code (AO) (German only)](https://www.bundesfinanzministerium.de/Content/DE/Downloads/BMF_Schreiben/Weitere_Steuerthemen/Abgabenordnung/2024-06-28-mitteilungsverpflichtung-nach-AO.html)
* [Start of the reporting obligation according to § 146a paragraph 4 Fiscal Code (AO) PDF (German only)](https://www.bundesfinanzministerium.de/Content/DE/Downloads/BMF_Schreiben/Weitere_Steuerthemen/Abgabenordnung/2024-06-28-mitteilungsverpflichtung-nach-AO.pdf?__blob=publicationFile&v=6)
* [Amendment of the application decree to the Fiscal Code (AEAO) regarding § 146a (German only)](https://www.bundesfinanzministerium.de/Content/DE/Downloads/BMF_Schreiben/Weitere_Steuerthemen/Abgabenordnung/AO-Anwendungserlass/2024-06-28-aenderung-aeao-146a.html)
* [Amendment of the application decree to the Fiscal Code (AEAO) regarding § 146a PDF (German only)](https://www.bundesfinanzministerium.de/Content/DE/Downloads/BMF_Schreiben/Weitere_Steuerthemen/Abgabenordnung/AO-Anwendungserlass/2024-06-28-aenderung-aeao-146a.pdf?__blob=publicationFile&v=4)

Starting January 1, 2025, new reporting obligations for electronic recording systems will come into effect. Businesses must report cash registers, EU taximeters, and odometers to the tax office. Specific deadlines starting January 1, 2025, are crucial. Find all the details in this article.

Starting in 2025, new rules for reporting electronic recording systems like cash registers and taximeters apply. Learn about deadlines and requirements!

New Reporting Obligations 2025: Cash Registers, Taximeters & Odometers

New reporting obligations for electronic recording systems from 2025

The cash inspection (Kassen-Nachschau) has been a central element of financial control in Germany since the beginning of 2018. It ensures the proper cash management and accounting of companies.

In this blog article, we take a closer look at the cash inspection and provide an overview of what you should look out for to be prepared for it.

## What is the cash inspection?

The cash inspection is an unannounced inspection of companies' cash records and systems by the tax authorities. It aims to prevent tax evasion and manipulation by ensuring that companies correctly record and pay taxes on their revenue. If discrepancies are discovered during the cash inspection, additional tax reviews, such as a comprehensive tax audit, may be conducted.

## What is the legal basis for the cash inspection?

For merchants to avoid possible sanctions, they must be informed about and comply with the legal obligations. According to Section 146b of the German Fiscal Law (Abgabenordnung, AO), the tax authorities have the right to conduct unannounced cash inspections during business hours. They may enter business premises, check documents and read data from cash register systems, but they may not take or open anything.

The contact person is the taxpayer or business owner, but the cash inspection can also take place in the presence of an employee with cash-handling responsibilities. In order to make the process more transparent and to be available at the relevant time, the Chambers of Crafts are calling for the mandatory announcement of a planned cash inspection and more precise guidelines.

## What happens during a cash inspection?

A cash inspection can take place without prior notice at any time during business hours. The auditors of the tax office can either appear incognito as a customer and make a hidden test purchase or carry out an obvious audit. In the case of test purchases in publicly accessible business premises, auditors do not have to identify themselves. Still, they must do so if access to further documents is required.

### **The following factors are examined:**

* #### **Is an electronic and tamper-proof cash register system in place?**

  The tax authorities check whether a cash register system is used that enables the keeping of electronic records. Particular attention is paid to whether the system meets the legal requirements and whether the data is protected against subsequent manipulation. [The interface for exporting data is regulated in the Digital Interface of the Tax Administration for Cash Register Systems (DSFinV-K).](/en/dsfinv-k)
* #### **Are cash records properly maintained?**

  [This includes, among other things, the continuous numbering of receipts](/en/articles/qr-code-replaces-tss-signature), the recording of the date and time for each transaction, the accurate recording of income and expenses, and the indication of the payment method.
* #### **Are cash records kept correctly?**

  Checks are carried out to ensure that the legal requirements for retaining cash register records are complied with. The retention period for companies and self-employed persons is generally ten years.
* #### **Do the cash balance and records match?**

  It is checked whether the cash on hand corresponds to the recorded income and expenses and whether the cash management is documented without gaps.

In the case of a cash inspection, the checks are usually carried out by inspecting the cash register records, reading out the electronic data, and questioning the business owner or employees. The aim is to ensure that cash management is correct and transparent in order to prevent potential manipulation and tax evasion.

## How to be prepared for the cash inspection

If the main contact person (such as management) is not always available, it is important to inform employees who regularly handle the cash register about a possible inspection and its requirements so that they can communicate with the auditors.

The cash inspection pays particular attention to the cash register systems used. These must comply with legal requirements and be tamper-proof. After the expiration of transitional periods at the beginning of 2023, [the German Cash Register Security Ordinance (Kassensicherungsverordnung or KassenSichV)](/en/articles/kassensichv-in-2023-what-will-change) states that [all electronic cash register systems must be equipped with a certified technical security system (TSS)](/en/kassensichv-tss-from-fiskaly). It is particularly [important that the used TSS is certified by the BSI (Federal Office for Information Security)](/en/articles/bsi-certification-of-tss) and that regular updates are carried out.

The cash inspection also checks for compliance with record-keeping requirements. Retailers must record and store their receipts without gaps. If an electronic cash register system is already in place, the audit is completed within a very short time, as all relevant data is automatically recorded and can be retrieved in a tamper-proof manner at any time. [The cloud-based and KassenSichV-compliant TSS from fiskaly can be easily integrated into your POS system.](/en/kassensichv-tss-from-fiskaly)

Due to [the receipt issue obligation](/en/articles/receipt-issuance-obligation-in-germany-background-effects-and-alternatives), the cash register inspection in the form of a test purchase with a visual inspection can also be carried out quickly, [as relevant secured TSS data is visible directly on the receipt via a QR code.](/en/articles/qr-code-replaces-tss-signature) If the QR code is not integrated on the receipt, access to TAR files with extended TSS data is required via the TSS in order to successfully complete the cash inspection.

## Summarized

To be prepared for a cash inspection, merchants should take several important measures. These include careful documentation of business transactions, regular training of employees in the use of the POS system, and compliance with the legal requirements for storage periods.

What is the cash inspection (Kassen-Nachschau) in Germany, how does it work, and what do companies need to consider for a successful audit? We provide an overview of everything you need to know on this topic.

What is the cash inspection (Kassen-Nachschau) and what is important for a successful audit in consideration of the KassenSichV? fiskaly gives an overview.

The cash inspection in Germany: What merchants should know

Alle Informationen zu Systemarchitektur und Zertifizierung der cloudbasierten TSE fiskaly SIGN DE zur Umsetzung der KassenSichV.

Architektur und Zertifizierung von fiskaly SIGN DE

Die Architektur von fiskaly SIGN DE

die-architektur-von-fiskaly-sign-de

The receipt issuance obligation (known as Belegausgabepflicht or Bonpflicht in Germany) came into force on January 1, 2020, at the same time as the Cash Register Security Ordinance (KassenSichV). This legal obligation stipulates that companies must hand out a receipt to their customer after every transaction. The measure aims to prevent cash register manipulation and tax evasion and also to strengthen consumer protection through transparency. In this blog article, we will give you a comprehensive overview of the topic as well as its implications for companies.

## What is the receipt issuance obligation?

[The obligation to issue receipts (Section 146a (2) of the German Fiscal Code, AO)](https://www.gesetze-im-internet.de/englisch_ao/englisch_ao.html#p1406) is a legal obligation in Germany, according to which a receipt must be issued for every transaction. It affects companies of all sectors and sizes that sell products or services directly to end customers.

[To be compliant with KassenSichV, the receipt must contain certain information](/en/articles/kassensichv-kassensicherungsverordnung-in-2024-what-will-change), including the cash register and TSS number, the start and end time of the transaction, the signature counter, and the verification value. [Since June 2021, the readable TSE signature on the receipt can be replaced by a verification QR code](/en/articles/kassensichv-in-2023-what-will-change).

## Why is there a receipt issuance obligation?

The introduction of the receipt obligation aims to ensure greater transparency and control in business transactions involving large amounts of cash. Issuing receipts for every business transaction ensures that all transactions are fully recorded and documented for tax audits. This enables tax authorities to more effectively verify companies' tax obligations. The receipt requirement also provides consumers with proof of their transactions and serves to protect consumers.

## Who is affected by the receipt issuance obligation?

In Germany, the receipt obligation applies in principle to all companies that operate an electronic cash register system and handle transactions with end consumers. The regulation applies regardless of the size of the company, so both small stores and service providers, as well as large companies and chains, must comply with the receipt issue obligation. Open cash registers are exempt from the regulation. However, there are certain specifications that may vary depending on regional regulations. Companies should therefore inform themselves about the exact legal requirements.

## Are there any exceptions to the receipt issuance obligation?

Anyone who can prove a factual or personal hardship can apply to the tax authorities for exemption from the obligation to issue receipts. This includes, for example, the sale of goods to a large number of customers not known by name. Another case is the unreasonable issuance of cash register receipts, although additional costs are not a sufficient argument.

## Criticism of the receipt issuance obligation

Since its introduction in 2020, the receipt requirement has been the subject of much debate, especially in the context of businesses with frequent but low-value transactions such as bakeries or kiosks. Frequently cited arguments include the unnecessary amount of paper printed, as customers are not required to accept the receipt, and it is often disposed of immediately. Time delays, for example in busy stores at peak times, can also be an annoyance for businesses.

## The digital receipt as a legally compliant alternative

Companies can also digitize their receipt handling and provide their customers with digital receipts. [By switching to electronic receipts, companies can save valuable resources, while being legally compliant](https://receipt.fiskaly.com/en). By [scanning a QR code](https://www.fiskaly.com/blog/static-and-dynamic-qr-code), customers receive the receipt directly on their smartphone without having to provide personal data.

Initially, this was only possible if customers explicitly agreed to receive a digital alternative instead of a paper receipt. In the meantime, however, the Federal Ministry of Finance (BMF) has simplified this regulation: The tacit consent of the customer to the electronic receipt is sufficient. In practice, this means that companies must inform customers about the digital receipt, but it is not mandatory to download it.

The receipt issuance obligation, also known as Belegausgabepflicht or Bonpflicht in Germany, has been in force since January 2020 as part of the KassenSichV. What is this obligation, what is the reason behind it, and how can you stay compliant? The answers can be found in this blog post.

At the beginning of the year, a further transitional period of the German KassenSichV expired and the regulation was enacted for all POS systems. Every electronic POS system must therefore be equipped with [a certified technical security system (TSS) ](/en/kassensichv-tss-from-fiskaly)as of January 1, 2023.

## The last transition period for POS systems has expired

On December 31, 2022, the transition period for POS systems that could not be retrofitted with a valid TSS due to their design, and were purchased between November 25, 2010, and before January 1, 2020, ended. This means that even GoDB-compliant POS systems that cannot be technically retrofitted may no longer be used as of January 2023. However, open cash registers remain legally compliant, provided the numerous record-keeping requirements are met.

## More security through a TSS

The KassenSichV stipulates that all cash register systems must be equipped with a TSS (Technical Security System). The TSS is an electronic security system that prevents the manipulation of digital cash register records. [The BSI (Federal Office for Information Security) is responsible for the certification. ](/en/articles/bsi-certification-of-tss)The fiskaly Cloud TSS is certified by the BSI and is easily integrated into your POS system.

## Receipt issuance obligation

[The receipt issuance obligation](/en/kassensichv-receipt-obligation-and-fiskaly) is regulated in the KassenSichV and must be implemented in 2023. The KassenSichV-compliant receipt contains data that the TSS secures. Therefore, the following data must be printed on the receipt:

* POS and TSS number,
* Start and end time of the transaction,
* signature counter and verification value.

The data can be stored in a QR code and does not have to be printed as plain text on the receipt. [The receipt may also be given to customers digitally.](https://www.fiskaly.com/digital-receipt) 

**(Update 2024)**

**From January 1, 2024**, the receipt in Germany must also include the **serial number of the ERS** and the **serial number of the TSS** in order to be KassenSichV compliant. Details about receipt requirements can be found in the [new version of the Application Decree to the Fiscal Code on Section 146a (AEAO) by the BMF](https://www.bundesfinanzministerium.de/Content/DE/Downloads/BMF_Schreiben/Weitere_Steuerthemen/Abgabenordnung/AO-Anwendungserlass/2023-06-30-AEAO-Par-146-AO.pdf?__blob=publicationFile&v=2).

## Reporting to the tax office - not yet possible

The registration of the POS at the tax office is also regulated in the KassenSichV. Companies must register or deregister electronic cash registers with the tax office. There is still (as of January 2023) no reporting software to report a POS to the tax office. The reporting procedure is expected to start in the fall of 2023. We will inform you of any updates.

## DSFinV-K and Kassen-Nachschau

In the context of external audits and Kassen-Nachschau, tax authorities can request the data collected by the TSS uniformly via DSFinV-K export. [The DSFinV-K (digital interface to the revenue administration for point-of-sale systems)](/en/dsfinv-k) describes an interface for the export of data from electronic recording systems for data medium transfer (Datenträgerüberlassung). The TSS has an export interface through which the standardized export of the stored and secured cash register records takes place. Via the standardized interface, the data can also be transferred to an archiving system.

If the legal requirements of the KassenSichV are not met, the Finanzamt (tax office) can estimate the basis for taxation during an audit. In addition, fines of up to €25,000 can be imposed.

Do you have any questions about German KassenSichV?

At the beginning of the year, a further transitional period of the German KassenSichV expired and the regulation was enacted for all POS systems. Every electronic POS system must therefore be equipped with a certified technical security system (TSS) as of January 1, 2023.

The transitional period of the German KassenSichV expired. Therefore every electronic POS system must be equipped with a certified TSS as of January 1, 2023.

KassenSichV in 2023 - What will change?

KassenSichV in 2023 - What will change

On 25 June 2021, the Bundesrat approved the ordinance amending the Cash Security Regulation. ([2](https://www.bundesrat.de/SharedDocs/drucksachen/2021/0401-0500/438-21.pdf?__blob=publicationFile&v=1))([4](https://www.bundesrat.de/SharedDocs/drucksachen/2021/0401-0500/438-21(B).pdf?__blob=publicationFile&v=1)) The addition to § 6 sentence 2 KassenSichV makes it possible that certain information does not have to be printed on a receipt in a form that can be read by a human being, but can be displayed in a QR code. This means that the size of the receipt can be reduced.
**Section 6 paragraph 2 of the KassenSichV is worded as follows.**
"The information according to paragraph 1 must be

1. be legible to anyone without machine assistance, or  2. be readable from a QR code.

The QR code according to paragraph 2 number 2 must correspond to the digital interface of the tax authorities (DSFinV), which is prescribed for the respective associated type of recording system. The digital interface shall be published on the website of the Federal Central Tax Office, as amended from time to time."

Source: [Bundesrat Drucksache 438/21 p. 8.](/img/bundesrat-drucksache-438-21.pdf)

Subject to paragraph 2, this Ordinance shall enter into force the day after promulgation.

**(Update 2024)** To ensure [compliance with KassenSichV starting from January 1, 2024](https://www.gesetze-im-internet.de/englisch_ao/englisch_ao.html#p1392), the receipt must include not only the TSS data but also the **serial numbers of both the electronic record-keeping system (ERS) and the TSS**. We recommend to store this data in the QR code.

## Sustainable development

The addition in § 6 sentence 2 KassenSichV makes it possible to print the signature data in a QR code. Previously, all data had to be printed in a human-readable form. This means that this data no longer has to be displayed twice on the receipt if a QR code has already been printed on the receipt. This means that cash register receipts will be shorter. It is estimated that this change will save 108 000 km of paper annually.

The structure and technical specifications for the QR code must comply with the digital interface of the tax authorities (DSFinV). For cash register systems, a digital interface of the financial administration for cash register systems (DSFinV-K) is defined.

## Save paper - use QR codes

The TSS data (=secured TSS data according to KassenSichV) should be stored in the QR code. This eliminates the need to print the TSS plain text on the receipt. This is the current recommendation of the tax authorities. In the event of a cash register inspection, the QR code simplifies the process. Shorter receipts save paper and therefore money. In addition, thermal paper pollutants are avoided and the environment is protected.
![Short and long receipt](/img/new-receipt-comparison-en-no-bg.webp "Short and long receipt")
The first receipt on the left shows the abbreviated version with the secured TSS data stored in the QR code. The second receipt on the right shows a receipt with printed plain text of the secured TSS data according to KassenSichV. Here, the difference in length and thus the saving of resources can be clearly seen.

Alternatively, you can switch to the digital [fiskaly receipt](https://receipt.fiskaly.com/) and thus dispense with thermal paper altogether. You will find more information about the fiskaly receipt below.

**QR code advantages overview:**

* Cash register inspection is significantly simplified
* Faster verification of receipts
* Paper savings → Costs are reduced
* Thermal paper pollutants are reduced → Environment is protected
* Aesthetically more beautiful receipts

## fiskaly receipt:

The "extra step" with fiskaly is the completely electronic receipt issuing. With the fiskaly receipt ([interface](https://developer.fiskaly.com/api/ereceipt/v1)) it is now possible to hand over the receipt 100% electronically and therefore climate neutral. For example, the handover can be done easily by a QR code. At the end of a transaction, the seller receives a QR code on his device. The customer can scan this QR code and receive his electronic fiskaly receipt directly on his device. Alternatives are sending the receipt by e-mail or SMS.

**fiskaly receipt advantages overview:**

* Digital receipt → no paper, no additional costs
* Seamless and fast integration through API interface
* Modern way of receipt issuing (QR code, email, SMS)
* No contact with thermal paper pollutants
* Aesthetically customizable design

**Note:**

It is estimated that this change will save 108,000 km of paper annually in Germany.

The example below illustrates how many resources can be saved annually by this change.

## Example calculation of resource saving

The example is from the Regulation on the Amendment of the Cash Security Regulation and illustrates how many resources can be saved annually through this amendment:

"Here it is assumed that the data so far takes up an average length of 3 cm on the cash register receipt and that approx. 40 percent of the receipts are either issued electronically or do not contain a QR code. With an estimated 6 billion receipts per year, this leads to a paper saving of 108,000 km of paper. With an average length of 50 m per receipt roll and an average cost of 1 euro per receipt roll, the annual savings amount to 2.1 million euros."

Drucksache 19/29085 (28.4.2021), p. 15.

fiskaly supports this sustainable development of printing a QR code instead of printing the readable signature. In this way, [paper consumption can be reduced by the document output requirement](/en/articles/receipt-issuance-obligation-in-germany-background-effects-and-alternatives) and thus resources can also be conserved.

## fiskaly eReceipt

The "extra step" with fiskaly is the completely electronic receipt issue. With the fiskaly eReceipt, it will be possible in the future to hand over the receipt 100% electronically and thus in a climate-neutral way.

More details will follow in summer 2022.

Sources:

1. [German Bundestag Drucksache 19/29085](https://dserver.bundestag.de/btd/19/290/1929085.pdf) 28.04.2021 
2. [Bundesrat Drucksache 438/21](https://www.bundesrat.de/SharedDocs/drucksachen/2021/0401-0500/438-21.pdf?__blob=publicationFile&v=1) 21.05.2021 
3. [Bundesrat Drucksache 438/1/21](https://www.bundesrat.de/SharedDocs/drucksachen/2021/0401-0500/438-1-21.pdf?__blob=publicationFile&v=1) 14.06.2021 
4. [Bundesrat Drucksache 438/21 (Beschluss)](https://www.bundesrat.de/SharedDocs/drucksachen/2021/0401-0500/438-21(B).pdf?__blob=publicationFile&v=1) 25.06.2021

The decision of the Federal Council allows a QR code to be printed as an alternative to the data issued in readable form. This can shorten a receipt and thus save costs as well as resources.

Federal Council's decision allows QR codes to be printed on cash register receipts as an alternative. This can shorten a document and save costs and resources.

QR code replaces legible TSS signature on receipt

Everything you need to know about the receipt issuance obligation in Germany. What is it, and who is affected? What are legally compliant alternatives?

The receipt issuance obligation: background, effects, and alternatives

die-bonpflicht-in-deutschland-hintergründe-auswirkungen-und-alternativen

[In Germany, the Cash Register Security Ordinance (KassenSichV)](/en/articles/overview-federal-states-ordinances-kassensichv), which has been in force since January 1, 2020, is essential for tax compliance. Important changes come into force in January 2024, affecting various aspects of business operations. In this blog post, we take a look at the legal updates and practical implications of these changes. Our aim is to equip you with the necessary knowledge to easily adapt to these requirements.

## What is the KassenSichV?

[The Cash Register Security Ordinance](/en/kassensichv-receipt-obligation-and-fiskaly#:~:text=experts%20for%20fiscalisation-,KassenSichV%20law,-The%20Cash%20Register) (KassenSichV) regulates the technical requirements for electronic recording and security systems in business transactions to ensure complete documentation of cash register transactions.

In order to meet the requirements of the KassenSichV, all electronic cash register systems must be equipped with a technical security system (TSS). This security system protects the digital cash register records against manipulation. [TSS certification](/en/articles/bsi-certification-of-tss) is carried out by the Federal Office for Information Security (BSI).

## TSS obligation for taximeters and odometers: Non-objection period until 2025

A far-reaching update of the KassenSichV for the technical requirements for electronic records in business transactions is relevant for cab and car rental companies.

Taximeters and odometers were previously [exceptions to the KassenSichV](https://datenbank.nwb.de/Dokument/858084/). As of January 1, 2024, they were included in the list of electronic record-keeping systems in accordance with [Section 1 (2) KassenSichV](https://www.gesetze-im-internet.de/englisch_kassensichv/englisch_kassensichv.pdf) – making them equal to electronic cash register systems. This change automatically requires taxi operators to comply with the [receipt issuance obligation](/en/articles/receipt-issuance-obligation-in-germany-background-effects-and-alternatives).

Following criticism from within the industry, the Federal Ministry of Finance (BMF) published a [non-objection regulation for the use of EU taximeters and odometers](https://www.bundesfinanzministerium.de/Content/DE/Downloads/BMF_Schreiben/Weitere_Steuerthemen/Abgabenordnung/2023-20-13-nichtbeanstandungsregelung-eu-Taxameter-wegstreckenzaehler_kopie.html) without a certified technical security device on October 13, 2023:

> In order to implement a nationwide upgrade, there will be **no objection** if these electronic recording systems do not yet have a certified technical security device **by December 31, 2025 at the latest.**

The implementation of TSS for taximeters including the digital interface of the tax authorities for EU taximeters and odometers (DSFinV-TW) has therefore been put on hold. 

We strongly recommended using this time to stay informed about the [retrofitting of taximeters](/en/articles/tss-and-dsfinv-tw-modification-in-taximeters-what-to-consider-for-taxes). We are also offering a cloud solution for compliance with the [KassenSichV for taxi operators](https://developer.fiskaly.com/api/sign-taxi/v0).

## Inclusion of electronic record-keeping system (ERS) and security module (TSS) serial numbers on the receipt

Another change to the KassenSichV 2024 concerns the [mandatory information on the receipt](https://www.bundesfinanzministerium.de/Content/DE/Downloads/BMF_Schreiben/Weitere_Steuerthemen/Abgabenordnung/AO-Anwendungserlass/2023-06-30-AEAO-Par-146-AO.pdf?__blob=publicationFile&v=2). **From January 1, 2024**, the receipt in Germany must also indicate the **serial number of the electronic record-keeping system and the serial number of the security module (TSS)** in addition to the TSS data already included:

> The receipt must contain at least the following information: (...) The serial number of the electronic record-keeping system and the serial number of the security module. The serial number recorded in accordance with § 2 sentence 2 no. 8 KassenSichV must be stated on the receipt.

– see [AEAO to Section 146a, No. 2.2.3.1 and 2.2.3.2](https://www.bundesfinanzministerium.de/Content/DE/Downloads/BMF_Schreiben/Weitere_Steuerthemen/Abgabenordnung/AO-Anwendungserlass/2023-06-30-AEAO-Par-146-AO.pdf?__blob=publicationFile&v=2)

You can find the cash register ID in your fiskaly dashboard as "Serial No.". If you are already a **fiskaly customer** and use the QR code on your receipts, you **do not need to make any further changes** to comply with the updates to the ID details. As the [receipt issuance obligation](/en/articles/receipt-issuance-obligation-in-germany-background-effects-and-alternatives) requires a receipt to be handed over for every transaction, you save resources by using shorter receipts and [simplify the cash inspection](/en/articles/cash-inspection-kassennachschau-in-germany-what-merchants-should-know).

If you have included the required data in plain text on your receipts, you must check them for completeness. We recommend storing the information in a QR code.

### What information must be included on the receipt?

#### Attention, from January 1, 2024, there is new mandatory information on the receipt!

From 2024, the receipt must contain the serial numbers of the electronic record-keeping system (ERS) and the security module (TSS), as well as the check value and the consecutive signature counter.

**Here is an overview of all information on the receipt in accordance with the KassenSichV in 2024:**

* Full name and address
* Date and time the receipt was issued
* Product quantity or scope of service
* Consecutive and unique transaction number
* Total amount and tax rate of the products or service sold
* Serial number of the electronic record-keeping system and serial number of the security module
* Amount per payment type
* Signature counter
* Check value

All details on the current requirements for receipts can be found in the [new version of the application decree on Section 146a AO by the BMF](https://www.bundesfinanzministerium.de/Content/DE/Downloads/BMF_Schreiben/Weitere_Steuerthemen/Abgabenordnung/AO-Anwendungserlass/2023-06-30-AEAO-Par-146-AO.pdf?__blob=publicationFile&v=2) (in German).

## Charging stations for electric and hybrid vehicles & Calibration law

In Germany, the [“Mess- und Eichgesetz” (MessEV)](https://www.gesetze-im-internet.de/messev/BJNR201100014.html) defines the standards for measuring devices for the purpose of consumer protection. To ensure transparency and legal compliance for public electric charging stations, electricity must be billed in kilowatt hours (kWh).

**Calibration law compliant EV charging stations must:**

* be equipped with calibrated and certified electricity meter
* issue clear prices and receipts (the **receipts must be KassenSichV compliant**)
* guarantee secure data transmission
* store measurement and data records for each charging process to enable subsequent verification

## Tax office report of the cash register

The tax office report of the cash register to the tax office is also specified in the KassenSichV. Accordingly, all electronic cash register systems must be reported digitally to the responsible tax office, but there is still no reporting software for this purpose. According to [Section 146a (4) sentence 2 AO](https://www.heimpel.com/download/bmf_schreiben/2019-06-17-einfuehrung-paragraf-146a-AO-anwendungserlass-zu-paragraf-146a-AO.pdf) (German), the notification must be made *"within one month of acquisition or decommissioning"*.

Together with the [tax authorities in Hesse](https://finanzamt.hessen.de/), we are currently working on a procedure for reporting cash registers to the tax office. After the **pilot phase in January and February 2024**, the nationwide introduction is **expected to follow in autumn 2024**. We will keep you informed about further updates.

What are the latest changes in the German Cash Register Security Ordinance (KassenSichV) for 2024? Learn all about the new requirements for receipts, tax reporting procedures, taximeters, and EV charging stations in this blog post.

KassenSichV compliant in 2024 with the fiskaly Cloud TSS. Stay updated on tax reporting, receipt requirements, and retrofitting of taximeters and odometers.

KassenSichV 2024 - Changes you should know about

KassenSichV in 2024 – What will change

The Federal Ministry of Finance informs in the letter dated August 30, 2023, how the costs arising from the implementation of the certified technical security system (TSS) and the standardized digital interface (DSFinV-TW) are to be treated for tax purposes.

The [Cash Register Security Regulation also includes EU taxi meters and odometers](/en/articles/tss-in-taximeter-and-odometer). These electronic recording systems and the digital records to be maintained with them must be protected by a TSS, and the data must be provided to the tax authorities via DSFinV-TW exports in the event of a [cash inspection](/en/articles/cash-inspection-kassennachschau-in-germany-what-merchants-should-know) or external audit.

**Here are the details on the tax treatment of the implementation costs:**

## TSS

The regulations for the TSS as an economic asset and the depreciation correspond to the regulations of the BMF letter dated August 21, 2020. This means that for cloud solutions, the ongoing fees are "usually immediately deductible as business expenses". More [information on retrofitting cash registers can be found in our blog](/en/articles/modification-of-cash-registers).

## Unified digital interface:

The standardized digital interface includes the interface for connecting the TSS to the electronic recording system and the digital interface of the financial administration for EU taxi meters and odometers (DSFinV-TW). The costs for implementing this interface are treated as ancillary acquisition costs of the "TSS" economic asset.

## Simplification rule:

Just as in the original regulation for cash registers, there is a simplification rule: For simplification purposes, the responsible authorities accept that the costs incurred by the initial retrofitting of existing EU taxi meters or odometers with a TSS and the expenses for the initial implementation of the standardized digital interface in an already established electronic recording system can be booked directly and in full as business expenses ([see letter dated 30.08.2023](https://www.bundesfinanzministerium.de/Content/DE/Downloads/BMF_Schreiben/Weitere_Steuerthemen/Abgabenordnung/2023-08-30-kassensichv-stl.-Behandlung-Kosten-Implementierung-TSE-EU-Taxameter-Wegstreckenzaehler.pdf?__blob=publicationFile&v=2)).

With this adjustment, EU taxi meters and odometers are now also included in the tax regulations concerning the implementation of a TSS. It is essential for companies that have implemented a TSS to be aware of these changes and act accordingly.

The letter is available for download on the [Federal Ministry of Finance website](https://www.bundesfinanzministerium.de/Web/DE/Themen/Steuern/Steuerverwaltungu-Steuerrecht/Betriebspruefung/BMF_Schreiben_Allgemeines/bmf_schreiben_allgemeines.html).

The Federal Ministry of Finance released a statement on August 30, 2023. In this statement, it clarifies how to handle tax implications for costs arising from the integration of TSS and DSFinV-TW-Exports into taxi meters and odometers.

Tax aspects of TSS and DSFinV-TW modification for EU taxi meters and odometers. fiskaly explains the current regulations from the Federal Ministry of Finance.

Modification of taxi meters and odometers: What to consider for tax purposes

Retrofitting of taxi meters and odometers: What to consider for tax purposes

die-kassen-nachschau-in-deutschland-was-händler-wissen-sollten

From January 1, 2025, e-invoicing will become mandatory for domestic B2B transactions in Germany. This initiative aims to combat VAT fraud while enhancing efficiency and digitalization in book-keeping.

The mandatory e-invoicing requirement in Germany was established under the “Act to Strengthen Growth Opportunities, Investments, and Innovation as well as Simplification and Fairness in Taxation”, known as the Growth Opportunities Act ([Wachstumschancengesetz](https://www.recht.bund.de/bgbl/1/2024/108/VO.html)), in March 2024.

## Invoices and electronic invoices: what’s the difference?

The distinction between invoices and electronic invoices is defined in § 2 of the [German E-Invoicing Regulation](https://www.bmi.bund.de/SharedDocs/downloads/DE/gesetzestexte/e-rechnungsverordnung.html) (E-Rech-V).

### What is an invoice?

The E-Invoicing Regulation defines invoices as "documents that settle a delivery or service, regardless of how this document is labeled in business transactions."

Invoices are categorized into the following formats:

* Structured data (XML, e.g., XRechnung)
* Unstructured data (e.g., PDF, TIF, JPEG, or Word formats)
* Hybrid data formats (e.g., ZUGFeRD)

### What is an e-invoice?

A valid e-invoice, according to the E-Invoicing Regulation, exists only if:

* The invoice is issued, transmitted, and received in a structured format
* The format allows for automatic and electronic processing of the document

For a valid e-invoice, it’s crucial that both data creation, transmission by the sender, and receipt by the recipient occur digitally.

## What data must an e-invoice include?

In addition to VAT-related invoice components, an e-invoice must additionally include:

* Routing identification number
* Bank details
* Payment terms
* The issuer’s email address
* Supplier and order number, if previously provided to the issuer

## When does e-invoicing become mandatory?

Starting January 1, 2025, all companies in Germany are required to receive e-invoices in B2B transactions. Previously, this obligation applied only to transactions with public-sector clients (B2G, e.g., government agencies, public institutions).

### Receiving e-invoices

As of January 1, 2025, the requirement to receive e-invoices takes effect, eliminating the precedence of paper invoices and the consent requirement for receiving them. This means that from this date, your business partners can send you e-invoices without needing your explicit agreement. VAT deductions must then be based on the received e-invoice, with no entitlement to an alternative invoice format, like a paper invoice.

## What are the transition periods for e-invoicing?

To allow companies time to adapt, transition periods for issuing e-invoices in B2B transactions have been established by the legislator:

* **Until December 31, 2026:** Companies may continue to send paper invoices or e-invoices in unstructured formats (e.g., PDF) if the recipient agrees.
* **From January 1, 2027:** Companies with a previous year’s revenue of more than €800,000 must issue e-invoices.
* **From January 1, 2028:** All companies, regardless of revenue, must issue e-invoices.

## Which formats are acceptable for a valid e-invoice?

From January 1, 2025, an e-invoice will be recognized as valid only if the required invoice data is in a structured electronic dataset within an XML file.

At that point, only structured electronic formats in compliance with the European standard EN 16931 will be considered valid e-invoices, allowing for further electronic processing. Unstructured formats like PDF are insufficient since they do not permit processing. Currently, formats such as XRechnung and the hybrid ZUGFeRD format meet the standard’s requirements.

### Invoicing with the ZUGFeRD format

ZUGFeRD (Central User Guide of the Forum for Electronic Invoicing Germany) is a hybrid invoicing format specifically designed for electronic invoicing in Germany. It combines a PDF document with an embedded XML file containing structured invoice data, providing both a readable and machine-processable invoice. This format complies with the European standard EN 16931, making it suitable for e-invoicing in B2B and B2G transactions throughout the EU.

### Invoicing with the XRechnung format

Unlike ZUGFeRD, the XRechnung format contains only structured XML data and is thus designed exclusively for electronic processing. Unlike hybrid formats, XRechnung does not include a readable PDF component.

## Does a PDF invoice fulfill the e-invoicing requirement?

Invoices in PDF format or other unstructured electronic formats like Word (DOCX), Excel (XLSX), or image files (e.g., JPEG) **will not meet e-invoicing requirements as of January 1, 2025**.

While they can be created, sent, and received electronically, they are merely digital representations of invoices and do not allow for electronic processing. Unstructured digital formats, like paper invoices, will be considered "other invoices" by law and, after the transition period, may only be used in exceptional cases.

## What is the importance of the GoBD for e-invoices?

The legal retention period of 10 years also applies to e-invoicing. As before, companies must adhere to the “Principles for Proper Record Keeping and Retention of Books, Records, and Documents in Electronic Form” ([GoBD](https://ao.bundesfinanzministerium.de/ao/2021/Anhaenge/BMF-Schreiben-und-gleichlautende-Laendererlasse/Anhang-64/anhang-64.html)). It’s crucial to store e-invoices in their original, structured electronic format, ensuring they meet the requirements for immutability upon storage.

## What are the benefits of electronic invoicing?

Implementing e-invoicing offers numerous benefits, helping companies and authorities operate more efficiently and cost-effectively. Key advantages include:

* **Automation:** Through digital transmission and processing, companies can further automate processes, such as automatic booking, reminders, and payment matching.
* **Cost savings:** By eliminating paper, printing, postage, and manual handling, invoicing costs are significantly reduced.
* **Time savings:** E-invoices can be sent and received instantly, shortening payment cycles by reaching the recipient faster.
* **Error reduction:** E-invoices use structured data formats that integrate directly into existing systems, minimizing manual input errors and reducing the need for corrections.
* **Sustainability:** Transitioning to digital invoices reduces paper consumption and associated environmental impacts, like CO₂ emissions from production and shipping.
* **Improved transparency and tracking:** E-invoicing provides clearer oversight and simplifies payment tracking. Data can be archived and searched more easily, streamlining invoice management.
* **Enhanced compliance:** E-invoices meet legal requirements for invoicing and archiving, with structured data transfer ensuring all legal requirements are met.

Companies should update their internal processes and IT systems in advance to meet these new requirements and ensure a smooth transition to e-invoicing.

fiskaly supports companies in adhering to fiscal regulations and digitizing receipts.

From January 1, 2025, e-invoicing will be mandatory for domestic B2B transactions in Germany. This initiative is intended to combat VAT fraud and at the same time promote efficiency and digitalization in accounting. Learn all about the transition period, benefits and the new legal requirements!

Interested? Contact our team.

The QR code: efficient, space-saving, and officially recommended! Did you know that tax authorities actively recommend storing signature data of the TSS (Technical Security System, German: TSE or Technische Sicherheitseinrichtung) on receipts using a QR code? Since 2020, companies have been required by the [Cash Security Ordinance (KassenSichV)](https://kassensichv.net/en/kassensicherungsverordnung) to display security-relevant data on receipts. However, instead of using valuable space on the receipt for plaintext data, a QR code allows you to work more efficiently while also speeding up the verification process for tax authorities. Saving time and resources not only sounds good but is also a step toward a more sustainable future.

## 1. Simplified verification by tax authorities

Tax authorities actively recommend using a QR code to efficiently and securely store TSS signature data. The QR code significantly simplifies [audits and inspections by tax authorities](https://kassensichv.net/en/articles/cash-inspection-kassennachschau-in-germany-what-merchants-should-know), as inspectors can quickly and accurately process the data digitally. Why make the audit process more complicated when it can be so much simpler?

### Advantages for audits:

* **Faster verification:** The scanning of the QR code enables fast and accurate verification of TSS data without manual reading.
* **Reduced error rate:** As the data is read digitally, the risk of reading errors, misunderstandings or manipulations is minimized.

Integrate the QR code now and ensure that future audits for your customers run smoothly and efficiently.

### Update 2024: new requirements for receipts

Since January 1, 2024, [additional requirements apply to receipts in Germany](https://kassensichv.net/en/articles/kassensichv-kassensicherungsverordnung-in-2024-what-will-change). Besides the TSS data, the serial number of the electronic recording system and the serial number of the security module must now be displayed on the receipt. The QR code offers an efficient and space-saving way to integrate this information and ensure that your receipts comply fully with the KassenSichV. If you have not yet implemented these updates, we recommend doing so as soon as possible to meet the current legal requirements.

## 2. Aesthetic benefits for your customers

Even though the space used by receipts may not seem like a major issue at first glance, many consumers appreciate shorter, tidier receipts. A QR code looks modern, reduces the amount of space required, and creates a clean, minimalist receipt. This can enhance the shopping experience for your end customers, as they have less paper to carry around. Another advantage: the focus remains on important information or marketing activities printed on the receipt, rather than the TSS signature. Less is often more—even on receipts!

## 3. Paper savings and cost reduction

Imagine how much paper your customers use daily for receipts—thousands of transactions can quickly add up. A QR code shortens receipts, saving paper and reducing costs. For all of Germany, it is estimated that using QR codes could save up to 108,000 kilometers of paper per year—enough to circle the Earth almost 2.7 times! (Source: [Deutscher Bundestag, Drucksache 19/29085, 28.04.2021](https://dserver.bundestag.de/btd/19/290/1929085.pdf); [Bundesrat, Drucksache 438/21, 21.05.2021](https://www.bundesrat.de/SharedDocs/drucksachen/2021/0401-0500/438-21.pdf?__blob=publicationFile&v=1)). Less paper also means lower costs for receipt rolls and a significant reduction in waste—a win-win situation.
Update your receipts and provide your clients with cost savings while actively contributing to environmental protection.

## 4. Sustainability and environmental protection

Any measure that reduces the use of thermal paper is a step towards a better future. By switching to QR codes or even [fully digital receipts](https://www.fiskaly.com/digital-receipt), you can help reduce the [impact of thermal paper pollutants](https://www.fiskaly.com/blog/paper-receipt-facts). Your company can not only save costs but also significantly reduce its environmental footprint. Show your customers that sustainability matters to you—and take the first step toward more environmentally friendly receipts.

## TSS data in the QR code: The change is worth it

Switching to QR codes for TSS signature storage offers numerous benefits: reduced paper consumption, simplified audits, lower costs, and a more sustainable solution for your customers' businesses. Moreover, with this solution, you are fully prepared for future legal requirements. With fiskaly, you can easily integrate these advantages into your POS system.
Integrate the QR code into your POS system now to ensure that your clients can work in compliance with regulations, efficiently, and in an environmentally friendly way. If you prefer a fully digital solution for your clients, learn more about our digital receipt. Contact our sales team for further details.

Switching to QR codes for TSS signatures offers numerous advantages: reduced paper usage, simplified audits, and a sustainable approach for your POS system. Ensure your compliance and efficiency with fiskaly.

How using a QR code for TSS signature storage can optimize receipts, simplify audits, and save costs. 2024 updates and 100% compliance with fiskaly's solutions.

TSS Signature in QR Code: Efficient Solutions for POS Systems

Why you should store the TSS signature in a QR code

From January 2025, e-invoicing will be mandatory for B2B transactions in Germany. Everything you need to know about the changes, benefits and new requirements!

Obligation for B2B e-invoicing from 2025: Implementation guidelines

Mandatory e-invoicing from 2025: A guide

e-invoicing-der-leitfaden-zur-verpflichtenden-e-rechnung-ab-2025

[The introduction of the technical security device (TSS)](/en/kassensichv-advantages-of-cloud-tss) for taximeters and odometers is approaching and brings some changes for taxi operators. From January 1, 2024, taximeters and odometers must have a TSS to protect digital basic records from unlogged changes and deletions. Here, we would like to give you a brief overview of what you should know about the introduction of TSS in taxis.

## New requirements in the application decree

The Federal Government has proposed in the [Application Decree to the Fiscal Code on § 146a AEAO](/en/articles/webinar-new-version-aeao-dsfinvk-reporting-obligation-in-2023) due to the inclusion of EU taximeters and distance meters within the scope of the Cash Security Ordinance (KassenSichV), how a taximeter equipped with TSS should look like.

The application decree has been fundamentally redesigned and is divided into four parts. Parts III and IV have been added for requirements concerning EU taximeters and odometers.

## Special requirements for taximeters and odometers

Since taximeters and odometers are only partially comparable in their technical functionality with electronic cash register systems, additional requirements for documenting business transactions and issuing receipts have been included in the application decree. These special requirements are intended to ensure that data is properly recorded and protected.

## Reactions from leading taxi associations to the introduction of TSS

Both the Bundesverband Taxi und Mietwagen e.V. (BVTM) and the Taxi- und Mietwagenverband Deutschland (TMV) have issued statements to the Federal Ministry of Finance expressing their approval of the new introduction of TSS. The associations welcome the measures and recognize the benefits of secure and tamper-proof recording of business transactions.

## Preparation for new requirements and transparency in the taxi industry

The introduction of TSS for taximeters and odometers brings changes for taxi operators. It is important to prepare for the new requirements. TSS serves to protect digital records and contributes to transparency and protection against manipulation in business transactions in the taxi industry.

fiskaly is working intensively on a solution to support taxi operators in implementing TSS. [For further information and individual consultation, feel free to contact our Sales Team.](/en/contact)

Taximeters and odometers must be equipped with a Technical Security System (TSS) from January 1, 2024. Here you will find further information on what you need to know about the introduction of TSS in taxis.

As a POS provider, it is crucial to be up to date on the latest developments regarding the new 2023 version of the Application Decree of the Fiscal Code (Anwendungserlasses der Abgabenordnung, AEAO). In our upcoming webinar, we offer you the opportunity to get a comprehensive overview about the innovations and requirements.

Our experts Elias Priesching and Oliver Abl will give you insights into the new Application Decree for the Fiscal Code (AEAO) as well as the changes for taximeters and odometers, coming into effect in 2024. In addition, you will learn why the DSFinV-K is so relevant for cash inspections and the current status of the reporting procedure for cash registers at the tax office.

After the webinar, you will be aware of the latest developments under the Cash Protection Regulation 2023:

* New version of the Application Decree to the Fiscal Code on Section 146a (AEAO) by the BMF
* The contents and effects of the AEAO on POS systems as well as taximeters and odometers
* Relevance of the DSFinV-K for cash inspections
* Current status of the reporting procedure for cash registers at the tax office

## Regulatory Updates: New version of AEAO, DSFinV-K and reporting obligation

**Datum und Uhrzeit:** Donnerstag, 20. Juli 2023, 11:00 CEST

[Register for the webinar](https://fiskaly.webinargeek.com/regulatorische-updates?cst=8)

**Please be aware that this webinar will only be available in German.**

Register now for our webinar and use this opportunity to update your knowledge. Get your questions answered by our experts. With fiskaly you are well informed and ensure that your company meets the new requirements!

As a POS provider, it is crucial to be up to date on the latest developments regarding the new version of the Application Decree of the Fiscal Code (Anwendungserlasses der Abgabenordnung, AEAO). In our upcoming webinar, we offer you the opportunity to get a comprehensive overview about the innovations and requirements.

As a POS provider, be informed about the 2023 updates to the Application Decree of the Fiscal Code (AEAO). The free fiskaly webinar provides a great overview.

New version of AEAO: Innovations & requirements for POS providers

New version of the AEAO: Innovations and requirements for POS providers

Germany starts Technical Security System in taximeters and odometers as stated in AEAO from 01.01.2024. fiskaly informs about what you need to pay attention to.

Introducing TSS for taximeters - BMF issues AEAO on § 146a

Introduction of TSS for Taximeters

einführung-der-tse-für-für-taxameter

## Only the fiskaly Cloud TSS V2 is the certified TSE!

The certified fiskaly Cloud TSS is stable and can now be integrated. To do this, migrate the system to V2.

## Migrate to the Cloud TSS V2 now!

Start now with the certified Cloud TSS from fiskaly. To do this, migrate the system from V1 to V2. With V2, we have revised and improved the system and incorporated your feedback. Thus V2 is our best and most stable system. 
Important! V2 is the only certified cloud TSE from fiskaly.

## Why is migration to V2 important?

You need to migrate to V2 to comply with regulatory requirements. By migrating to V2, you can expect a revamped system that works better and is more stable than V1.

## The advantages at a glance

* V2 is THE certified Cloud TSS from fiskaly 
* Even better system 
* Even more stable system 
* Customer feedback has been taken into account 
* Higher customer satisfaction

For questions, please contact our Sales Team at [sales@fiskaly.com](mailto:sales@fiskaly.com).

Why the migration to the fiskaly Cloud TSS V2 is important and you should definitely implement it now, you will learn in this article.

fiskaly Cloud TSS migration V1 to V2

fiskaly-cloud-tse-migration-v1-zu-v2

## fiskaly Cloud TSS as the only Cloud TSS with certificate duration until 2029

With the completion of the certification process, fiskaly is the only Cloud TSS to achieve the full certificate term and is **certified until 2029**. The fiskaly Cloud TSS is 100% software-based and can be integrated into all systems and cash register architectures.

> More than two years of planning, postponements, hurdles and changes, as well as improvements to the requirements are behind us. Now the time has finally come! The certified fiskaly Cloud TSS is the first Cloud TSS to be certified for the full period! I am very proud of fiskaly and the incredible team effort over the past months. 

Johannes Ferner, CEO fiskaly GmbH 

## Hard Facts fiskaly Cloud-TSE

* Only Cloud TSS with the maximum **certificate term until 2029**! 
* **True Cloud TSS** without additional hardware requirements like a TPM module! 
* Scalable operation & roll-out! 
* Open for innovative trading concepts!

## Download the certificates

We are pleased to present you our certificates:

### CSP-L Certificate

### [![CSP‑L Zertifikat](/img/scpl.webp "CSP‑L Zertifikat")](/img/cspl-zertifikat-fiskaly_-bsi-dsz-cc-1130-2021-ou-1-.pdf)

### SMAERS Certificate

### [![SMAERS Zertifikat](/img/smaers-zertifikat.webp "SMAERS Zertifikat")](/img/SMAERS-Zertifikat-fiskaly_BSI-DSZ-CC-1130-2021.pdf)

### TR-Certificate

### [![TR-Zertifikat](/img/tr-zertifikat.webp "TR-Zertifikat")](/img/tr-zertifikat_fiskaly_bsi-k-tr-0403-2021.pdf)

### ![](/img/logo-igztk.webp) IGZTK - Become a member

We would like to refer you to the IGZTK - Interessensgemeinschaft Zukunftsweisender Technologiehersteller für Kassensysteme - and would like to suggest a membership to you: [www.igztk.com](http://www.igztk.com)

The fiskaly Cloud TSS has now been fully certified by the German Federal Office for Information Security (BSI)! 🚀

fiskaly Cloud TSS certified 🚀

fiskaly-cloud-tse-zertifiziert-🚀

With the fiskaly Dashboard you have insights into your products which you have booked with fiskaly. The Dashboard allows you to create and manage organisations and their users, see which transactions have already been started and which clients and technical security system (TSS) have been created. It visualises your data and you can see at a glance what is happening in the fiskaly system.

## Register for free with the fiskaly Dashboard
![Log-in-Dashboard_english_fiskaly-Dashboard-and-Management-API](/img/user-rights-tss-clients-transactions-exports-integrations-archive-organisational-management-user-management-signature-and-transaction-monitoring-accounting-1-.webp)
To use the fiskaly Dashboard, you need your own account. You can create one free of charge. All companies that you create in the test can also be switched to live mode after signing the contract.

[Click here for the Dashboard](https://dashboard.fiskaly.com/)

Info: When you log in for the first time, you must create a main organisation. After that you have the option to create your main and sub organisations via the dashboard or via the management API.

### fiskaly Dashboard Manual
The detailed [Dashboard manual is available on the fiskaly developer website](https://developer.fiskaly.com/en/docs/guides/dashboard).

## Management API
Via the Management API you can also solve all functions of the Dashboard programmatically. Only the first main organisation has to be created via the Dashboard. The detailed documentation of the interface functions with their parameters can be found on the [fiskaly developer website](https://developer.fiskaly.com/api/management/v0/). 
In the Management API, the terms **Organisation** are used for main organisation and **Managed Organisation** for managed organisation.

## Organisations and user rights
In the fiskaly system, a distinction is made between main organisations and managed organisations. What the difference is and how this affects user rights is described below.
All information about the organisations can be found on the [fiskaly developer website](https://developer.fiskaly.com/api/management/v0/#tag/Organizations) or in the [Dashboard user manual](https://developer.fiskaly.com/en/docs/guides/dashboard).

### What is a main organisation?
A main organisation is an authoritative unit in the fiscal system. It usually represents a holding, business or branch office. Main organisations can be created free of charge via the dashboard. Managed organisations (in the fiskaly system: managed organizations) can be attached to them. Managed organisations can also be managed via the main organisation.
In the organisation management, additional organisations can be created, information can be viewed, the organisation can be switched to live mode, an organisation logo can be stored, users can be organised, API keys can be created for the main organisation and API keys can be created for the managed organisations.

**Important: A main organisation cannot be a managed organisation of another main organisation.**

### User rights in the main organisation
Users of the main organisation, as well as persons invited to the main organisation, have access to all information displayed in the dashboard of the main organisation as well as to the information of the attached managed organisation(s) of this main organisation. I.e. overview dashboard, TSS number(s), client(s), transactions, exports, integrations etc. are displayed to the users.
![fiskaly user rights](/img/user-rights-tss-clients-transactions-exports-integrations-archive-organisational-management-user-management-signature-and-transaction-monitoring-accounting.webp "fiskaly user rights")

### What is a managed organisation?
The managed organisation is dependent on its superior main organisation and can never stand alone. It must always be subordinate to a main organisation. Managed organisations are given the badge "managed". They can also be created via the dashboard.
![create organisation](/img/screenshot_1_fiskaly-dashboard-und-management-api-261x300.webp "create organisation")

### User rights in the managed organisation
Users who are activated for the managed organisation only have access to the information of the respective managed organisation. The users have no insight into the information of the super-ordinate main organisation. Within the managed organisation, users have access to the dashboard and all the information stored there.

### How to create a managed organisation
In the **Dashboard**, in the menu item *Settings > Organisation Management*, click on the button *Create new organisation* and select the box *Create managed organisation*. Then specify under which main organisation this managed organisation should be created.

Under this link you will find how to [create the managed organisation via the Management API](https://developer.fiskaly.com/api/management/v0/#operation/createOrganization).
Make sure that the *ManagedOrganisation* button is selected.
![create managed organisation](/img/screenshot_2_fiskaly-dashboard-und-management-api-300x160.webp "create managed organisation")

### Difference between a main organisation and a managed organisation
In the fiscaly system, a distinction is made between main organisations and managed organisations. Managed organisations are dependent on the main organisation. They cannot themselves contain any other managed organisations. Similarly, a main organisation cannot be a managed organisation of another main organisation. It is important to know that the user rights of main organisations and managed organisations differ.

### Difference in user rights in main and managed organisations
Users of main organisations or managed organisations have access to the information displayed in the dashboard of the respective organisation. The user rights within the main organisation and the managed organisation differ in that users of the main organisation also have access to the information of the respective linked managed organisations. Users of the managed organisations, however, do not have access to the information of the parent main organisation.

### API Keys
At least one API key must be created at the organisation level. 

Via the dashboard in the menu item *Developer > API Key* click on the button Create API Key and select a name for the new API Key. Then select Create. 
![new API key](/img/screenshot_3_fiskaly-dashboard-und-management-api-e1600269690310-300x144.webp "new API key")
**Attention: the API Secret is only displayed immediately after the creation of a new API Key!**
![new API key 2](/img/screenshot_4_fiskaly-dashboard-und-management-api-e1600269732594-300x153.webp "new API key 2")
[API Keys can also be generated via the Management API.](https://developer.fiskaly.com/api/management/v0/#operation/createApiKey)

The API key of the main organisation can be used to manage the managed organisations. A separate API key must be created for each managed organisation in order to create a TSS for it and to use the other functionalities of the fiskaly SIGN API.
API Keys for main organisations must be created via the Dashboard or the Management API. For managed organisations, API Keys can be generated automatically.

An API Key is bound to an organisation and to the selected mode (Test/Live). This means that each API key can only be used for its own organisation. Exception: API Keys of a main organisation can be used for the respective managed organisations.

If the API key was created in test mode, it can **only(!)** be used to create entities for test purposes. With a key created in live mode, **only(!)** live entities can be produced. I.e. in a live organisation, further managed organisations can be created with the live API key, so that each managed organisation does not have to be switched individually to live mode.

On the fiskaly developer page you can find all [information about the API Keys](https://developer.fiskaly.com/api/management/v0/#tag/API-Keys) here.
![fiskaly API keys English](/img/info-to-api-keys.webp "fiskaly API keys English")

### Billing options
There are two ways to control the billing:

##### Bill_to_Organisation 
With the *Bill_to_Organisation* option, the bill is sent to the main organisation and can also be viewed via the dashboard.

##### Withhold Billing 
With the *Withhold Billing* option, the bill is not made to this managed organisation and can also not be viewed via the dashboard. For example, the fiskaly TSS can be sold as part of a checkout package without your customer seeing the price of the fiskaly TSS.

On the fiskaly developer page, all [Information on Billing](https://developer.fiskaly.com/api/management/v0/#operation/createBillingAddress) can be found here.
![fiskaly Info about Billing](/img/info-about-billing.webp "fiskaly Info about Billing")

## Organisational structure
#### Cash register manufacturer offers fiskaly Cloud TSS in its portfolio 
A cash register manufacturer uses fiskaly Cloud TSS for its cash register software. He offers three solutions to his customers. Typically, point 1. is best practice for large cash register providers. Point 2. and 3. are designed for more complex models.

Contact our sales team for this: [sales@fiskaly.com](mailto:sales@fiskaly.com).
![Organisational structure](/img/organisational-structure.webp "Organisational structure")

**1. Individual customers - best practice**
Under the main organization of the cash register manufacturer, individual customers are created and managed as managed organizations. The main organization is used to create the respective API Key of the managed organization. The billing option was set to Withhold Billing, as the price of the fiskaly Cloud TSS is included in the total bill of the POS manufacturer to the customer.

**2. Enterprise customers**
The POS manufacturer creates the Enterprise customer's holding company as the main organization. The Enterprise customer's branches are created as managed organizations. The main organization of the Enterprise customer is created with the API Key of the main organization of the POS manufacturer. It is up to the POS vendor whether the Enterprise customer manages its organizations itself or is managed by the POS vendor. The billing options are set to Withhold Billing for the Enterprise customer's organizations.

**3. White label partner**
The POS provider creates the White Label Partner company as the main organization. The White Label Partner's customers are created as managed organizations. The main organization of the White Label Partner is created with the API Key of the main organization of the POS manufacturer. The White Label Partner manages its customers (managed organizations) itself. The billing options are set to Withhold Billing for the organizations of the White Label Partner's customers.

For other models or special cases contact our sales team: sales@fiskaly.com.

### Download
Here you can download the article **fiskaly Dashboard and Management API** as a .pdf file.
[![fiskaly-Dashboard-und-Management-API_2020.pdf](/img/fiskaly-dashboard-management-api.webp "fiskaly-Dashboard-und-Management-API_2020.pdf")](/img/fiskaly-Dashboard-und-Management-API_2020.pdf)

The fiskaly Dashboard gives you an insight into your products which you have booked with fiskaly. Also you can see at a glance what is happening in the fiskaly system.

fiskaly Dashboard gives you an insight into your products which you have booked with fiskaly. Also you can see at a glance what is happening in fiskaly system.

fiskaly Dashboard and Management API

fiskaly-dashboard-und-management-api

## Support for digitalisation for businesses
Applications for Bridging Assistance III must be submitted by 31 August 2021 via their tax advisor, or elected representative (see item: [Where can Bridging Assistance III be applied for?](/articles/subsidies-for-digital-cash-register-systems)).

Digital cash register systems as well as "acquisitions and expansion of electronic recording systems within the meaning of §146a of the German Fiscal Code (Abgabenordnung AO)" ([FAQ](https://www.ueberbrueckungshilfe-unternehmen.de/UBH/Redaktion/DE/FAQ/FAQ-Ueberbrueckungshilfe-lll/ueberbrueckungshilfe-lll.html) 2.4, point 14) can be supported by the bridging aid III. Bridging aid III can be applied for in the event of a drop in turnover caused by the Corona restrictions for the period November 2020 to June 2021 and does not have to be repaid.

## Who can apply for the bridging assistance?
Businesses, solo self-employed and freelancers are supported by the Bridging Aid III and can receive, among other things, a one-off grant of up to 20,000 euros in digital investments. The subsidy does not have to be repaid. Taxpayers can now get support for their new digital cash register with TSE.

## Subsidy for digitalisation: electronic cash register systems with TSE are supported
The subsidy supports investments in digitalisation with up to 20,000 euros (one-time). This includes the acquisition costs of licence fees for IT programmes, IT hardware and licence fees. In the FAQ's of the Bridging Assistance III website of the federal government, you will find information on this under points 2.4 item 9 (business licence fees) and item 14:

*"In addition, under the same conditions, investments in digitisation (\[...] if they are necessary for the exercise of the business or self-employed activity) may be recognised as eligible for a one-off payment of up to 20,000 euros.*

**Also eligible are the acquisition and expansion of electronic recording systems within the meaning of § 146a of the German Tax Code (AO)."**

Source [FAQ on Bridging Assistance III](https://www.ueberbrueckungshilfe-unternehmen.de/UBH/Navigation/DE/Dokumente/FAQ/Ueberbrueckungshilfe-III/ueberbrueckungshilfe-lll.html)

The necessity of the conversion is given by the changed legal framework conditions through  §146a AO.

## Where can bridging assistance III be applied for?
Tax advisors, auditors, sworn accountants, tax agents or lawyers can apply for the bridging assistance on behalf of taxpayers. Costs for these services are partially eligible under Bridging Assistance III. You will receive detailed information from your representative. The deadline for applications is 31 August 2021.

### In brief: Information on Bridging Assistance III
**Prerequisite:** Sales decline caused by Corona restrictions (min. 30% compared to the respective reference month 2019) for the period from November 2020 to June 2021

**Funding opportunities in the digital sector:** Investments in digitalisation including IT licence fees, IT hardware, subscriptions and other fixed expenses (e.g. ongoing costs for external IT service providers).

**Eligible parties:** Companies with up to 750 million turnover/year, solo self-employed and freelancers.

**Applicant:** Application is made via third parties (e.g. tax advisors, lawyers, etc.)
Detailed information adapted to your case can be obtained by taxpayers from your tax advisor or elected representative.
You can find more information [here](https://www.ueberbrueckungshilfe-unternehmen.de/UBH/Redaktion/DE/FAQ/FAQ-Ueberbrueckungshilfe-lll/ueberbrueckungshilfe-lll.html).
You are welcome to talk to us as a first step.

**Disclaimer:**
fiskaly assumes no liability for the completeness or timeliness of this information. All information is provided without guarantee. This information does not constitute legal advice nor tax advice. Please contact your lawyer or tax advisor for binding clarification of relevant legal or tax issues.

Here you will find the most important information on supporting businesses with the Bridging Aid III (Überbrückungshilfe III) with grants of up to 20,000€ on investments in digitalisation. In this article, the focus is on costs incurred through §146 AO (KassenSichV).

The most important information on supporting companies with Bridging aid III on investments in digitalisation. Focus is on costs through §146 AO (KassenSichV).

Subsidies for digital cash register systems: Bridging aid III (Überbrückungshilfe III)

Subsidies for digital cash register systems: Bridging aid III

fördermittel-für-digitale-kassensysteme-überbrückungshilfe-iii

## Exchange with financial authorities

As experts in the field of fiscalisation, we are in regular contact with many financial institutions and the responsible persons. We are pleased to be able to conduct this joint exchange in order to implement the introduction of fiscalisation in Germany as efficiently as possible, together with our partners and other stakeholders involved. Accordingly, we would like to share our knowledge and the experience we have gained so far.

## Announced cash audit

This week (week 38, 2021) we supported a customer of the POS provider Tentaworks - member of the** [IGZTK](https://igztk.com/)** (Interest Group Future-oriented Technology Manufacturers for POS Systems) - during an announced cash register inspection. From the tax authorities, the highest tax authority of a federal state as well as the local tax authority were present in order to clarify open questions from all sides in a short way.

## Our conclusion from the joint cash inspection

Tax authorities carry out checks to ensure the use of a TSS and other legal requirements (e.g. implementation of the DSFinV-K). The joint cash inspection was very conscientious. In addition to the audit of general tax-relevant requirements, the use of the TSS and other requirements relevant to the German Cash Security Ordinance (KassenSichV) were of course also audited. A central element of the audit were the prescribed exports, the TAR exports from the TSS as well as the [DSFinV-K](https://www.bzst.de/DE/Unternehmen/Aussenpruefungen/DigitaleSchnittstelleFinV/digitaleschnittstellefinv_node.html). For example, LIVE bookings were carried out and then the exports were requested in order to be able to evaluate that these business transactions carried out are also evident in the records. It should be noted that the procedural documentation is an important document and should also explain how financial auditors and taxpayers arrive at the respective exports. This is very helpful for the entire process of the cash audit.

## On the operation of the fiskaly Cloud TSS

There were no complaints about the operation of the TSS itself. We are of course very pleased about this. The environmental protection was checked as a sub-step. After the operation of the TSS is carried out by fiskaly, it results that the components worth protecting are outside the access range of the attackers anyway - guaranteed. The higher level of protection of a cloud TSS due to this fact was also clear to the persons of the fiscal authorities.

## Procedural documentation

The procedural documentation must contain how taxpayers can create the exports of the TAR files as well as the DSFINV-K export so that they can be handed over to the tax authorities without any problems during the cash register inspection. fiskaly recommends making the exports available directly from the POS system. This is very easy to do via our APIs.

## Important!

Do you not yet have a solution in your POS system to create DSFinV-K exports? With fiskaly you can easily connect the creation of DSFinV-K exports to your POS system via API. Please contact our sales team: **[sales@fiskaly.com](mailto:sales@fiskaly.com)**

*The information contained on this website is for general information purposes and does not relate to the specific situation of any individual or legal entity. It does not constitute legal or tax advice. In a specific individual case, the present content cannot replace individual advice by competent persons.

## Further information

Sign up for our **Newsletter** and stay up to date with developments around the **Cash Protection Regulation**.

Tax authorities, POS provider Tentaworks and fiskaly, as experts in fiscalisation, conducted a joint cash register inspection this week. 

Joint cash inspection with tax authorities

gemeinsame-kassen-nachschau-mit-finanzbehörden

The Cash Register Security Ordinance (KassenSichV) regulates, among other things, the reporting of cash registers to the tax office. Accordingly, all electronic cash register systems must be reported digitally to the responsible tax office, but there was no standardized reporting software for this yet. In a unique pilot project with the Hessian tax authorities and industry partners, fiskaly is working on the technical implementation of the reporting obligation. On the occasion of the successful pilot project, we cordially invite you to our webinar.

Our fiscalization experts Elias Priesching and Oliver Abl will guide you through the webinar. They will give you a comprehensive insight into everything you need to know about the reporting obligation and introduce the [fiskaly SIGN DE x Submission API](https://developer.fiskaly.com/de/api/sign-de/submission/v1).

## After the webinar, you will know everything about

* **Tax office report of the cash register:** KassenSichV and the current status of the reporting obligation in accordance with Section 146a (4) AO
* **Important dates for implementation:** Implementation for digital reporting of electronic cash register systems to the tax office
* **fiskaly SIGN DE x Submission API:** Details on the cooperation between fiskaly and the Hessian tax authorities
* **Pilot phase and nationwide introduction:** First successful tax office report and details on the expected nationwide implementation

Our fiscalization experts Elias Priesching and Oliver Abl will guide you through the webinar. They will provide you with a comprehensive insight into everything you currently need to know about tax office reporting of the cash register and present the successful joint pilot project with the Hessian tax authorities and the fiskaly SIGN DE x Submission API.

Webinar: Tax office report of the cash register according to Section 146a (4) AO, pilot project of fiskaly and the Hessian tax authorities on digital tax office reporting and fiskaly SIGN DE x Submission API.

Webinar: "Simple POS reporting obligation with fiskaly"

jahressteuergesetz-2024-stärkt-kassensicherheit

Contact us!

kassensichv-2023-was-ändert-sich

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Don't miss any updates ✉️

kassensichv-2024-–-was-sich-ändert

## New version of the DSFinV‑K

Version 2.3 of the digital interface to the revenue administration for point-of-sale systems (DSFinV‑K) has been published by the Federal Central Tax Office. The DSFinV‑K interface is a legal requirement that must be implemented. The fiskaly DSFinV‑K is easy to implement.

## fiskaly solution

With the Cloud TSS fiskaly SIGN DE and fiskaly DSFinV‑K, you have an all-round worry-free package for the KassenSichV from one provider. At fiskaly, we automatically implement the legally binding changes and inform you about relevant updates..

## The most important updates

\- Change to serial number

\- New, supplemented overview of the sales tax keys

\- Additional clarifications as well as explanations of certain scenarios

\- [English translation](https://dsfinvk.fiskaly.com/api/v1/_docs/dsfinvk/dsfinv_k_v_2_3_eng_version.pdf) available — this is not legally binding

\- DSFinV‑K 2.3 must be applied by July 1, 2022 at the latest

## What is the DSFinV‑K?

DSFinV‑K is the description of an interface for data export from electronic record systems for data transfer. This is required for audits and Kassen-Nachschau inspections. 

## What do the changes to DSFinV‑K 2.3 entail?

Here we have compiled brief explanations of the most important changes for you.

##### Serial number

Previously, the POS serial number was stored in the technical security system (TSS). With DSFinV‑K 2.3, this must now also be stored in the DSFinV‑K. Note: For technical reasons, neither slashes (“/”) nor underscores (“_”) may be used in the POS serial number. 

##### **Clarifications**

DSFinV‑K 2.3 contains many clarifications on scenarios concerning the correct integration of the interface.

##### **English translation**

The [DSFinV‑K 2.3 is also available as an English translation](https://developer.fiskaly.com/dsfinvk/introduction#legal-requirements). The translation is not legally binding.

##### **Application regulation**

DSFinV‑K 2.3 applies to records made on or after July 1, 2022. Version 2.3 can also be applied before that.

## fiskaly DSFinV‑K

fiskaly offers a simple add-on solution to the Cloud TSS fiskaly SIGN DE to create statutory DSFinV‑K exports. You can easily integrate the function into your POS system via API. With fiskaly, you have the best partner for the implementation of the DSFinV‑K. We take care of the correct implementation of the legal requirements for you.

## [Test fiskaly DSFinV‑K now](https://developer.fiskaly.com/api/dsfinvk/v1)

The DSFinV‑K version 2.3 contains current updates and clarifications. fiskaly team has summarized the most important information for you.

The DSFinV‑K version 2.3 contains updates and clarifications. fiskaly team has summarized the most important information for you.

New requirements of DSFinV‑K 2.3

neue-anforderungen-der-dsfinv-k-2-3

Get Webinar Recording: Application Decree to AEAO by BMF + Reporting & DSFinV-K Updates in 2023

neufassung-des-aeao-neuerungen-und-anforderungen-für-kassenanbieter

Watch webinar recording: "Simple POS reporting obligation with fiskaly"

new-reporting-obligations-for-electronic-recording-systems-from-2025

As a rule, the taxable person must be able to provide the following documents during a cash register inspection:
1. proof of the TSS by purchase or contract 
2. linking of the TSS through test documents 
3. use of a certified TSS (certificate with all documents, see below) 
4. TAR/DSFinV-K exports 
5. procedural documentation

## 1. Proof of TSS through purchase or contract
Proof of purchase or contract of the TSS arises when your clients enter into a business relationship with you.

## 2. Linking of the TSS through test documents
Taxpayers can also generate this evidence independently. However, point out to your customers that you need this proof for the proper operation of your cash register. The receipts can be checked using the app fiskalcheck from fiskaly.

## 3. Use of a certified TSS
The certification of the technical security device is proven via the following documents: 
1. certificate according to TR-03153
2. conformity report
3. certificate of conformity 
4. environmental protection concept 

We recommend including these documents in your procedural documentation. 

**Attention! Proof of certification requires all of the above documents. If a document is missing, the proof is incomplete!**
All required documents of the fiskaly Cloud TSS can be downloaded from our website.

## Download Certificates
### Certificate according to TR-03153

[![Zertifikat nach TR-03153](/img/tr-zertifikat_fiskaly_bsi-k-tr-0403-2021.webp "Zertifikat nach TR-03153")](/img/tr-zertifikat_fiskaly_bsi-k-tr-0403-2021.pdf)

### Certificate of conformity
### [![Konformitätsbescheid](/img/konformitätsbescheid-fiskaly.webp "Konformitätsbescheid")](/img/BSI-K-TR-0403-2021_TR-Konformitaetsbescheid_fiskaly_TSE-cdf483bf726c385caf7527c4f99f803f.pdf)

### Conformity report
### [![Konformitätsreport](/img/fiskaly-konformitätsreport.webp "Konformitätsreport")](/img/BSI-K-TR-0403-2021_TR-Konformitaetsbericht_fiskaly_TSE-1705c4b9bf53a5fa36f734dbf9b2e7c2.pdf)

### Environmental protection concept
### [![Umgebungsschutz](/img/umgebungsschutz.webp "Umgebungsschutz")](/img/fiskaly-Umgebungsschutzkonzept-1-.pdf)

## Pay attention to the certificate duration of the TSS as well as the duration of the BSI certification.
The certificate terms of the TSS manufacturers differ greatly. Therefore, check the certificate duration of the TSS you use. With fiskaly you have a strong partner on your side and the only cloud TSS with full certificate duration until 2029.

## 4. TAR/DSFinV-K exports
The data generated by the TSS, called TAR Files, are usually provided once a day and must be included in the long-term archiving. The cash register data as well as the TAR files are checked in the event of an audit - cash register inspection or cash register audit - and must be available to the auditor at all times.
This legal requirement is already automatically covered when using the fiskaly Cloud TSS. 
All companies that use an electronic or computer-based cash register system must use a uniform structure for data entry and data export. This is regulated on the basis of the DSFinV-K (digital interface of the tax authorities for cash register systems) and is a uniform data standard. The corresponding data export interface is part of the TSS.

## 5. Procedural documentation
The procedure documentation should be handed over to the taxpayer by the cash register manufacturer when purchasing/contracting a cash register. Among other things, it documents the commissioning and connection of the TSS by the cash register manufacturer/ERS manufacturer. The DFKA provides sample procedural documentation on its website. 
[DFKA sample procedural documentation for proper cash management](https://dfka.net/wp-content/uploads/2019/04/VD-Kassenf%C3%BChrung_Stand_April-2019.pdf)
fiskaly recommends, provide your customers with all required documents for the proper operation of the cash register.

\*The information contained on this website is for general information purposes and does not relate to the specific situation of any individual or legal entity. It does not constitute legal or tax advice. In a specific individual case, the present content cannot replace individual advice by expert persons.

In this article you will learn which documents you need to provide to your customers for the proper operation of a cash register. Support your customers and make it easier for them to access the documentation.

What documents do you need to provide to customers for proper operation of a cash register? Make it easy for your customers to access documentation.

Necessary documents for the cash audit

notwendige-dokumente-für-die-kassenprüfung

qr-code-ersetzt-lesbare-tse-signatur-auf-kassenbeleg

The majority of the federal states have now reacted to the new publication of the BMF's non-objection regulation to the KassenSichV. Read below the notifications of the individual states and how this affects the implementation of the technical security system (TSS).

###### **Baden-Württemberg**

The Ministry of Finance of Baden-Württemberg issued a clarifying decree on 11 September 2020. Thus, it remains the case in Baden-Württemberg that if the requirements of the decree of 10 July 2020 are met, the implementation of the technical safety device must take place as soon as possible and by 31 March 2021 at the latest. We were informed of this in response to our enquiry.

###### **Bavaria**

[Bavaria Message of 16 September 2020](/img/bayern_stmf_14.09.2020_elektr._kassen.pdf)

"By way of clarification, I would like to point out that the decree of the Bavarian State Ministry of Finance and for Home Affairs of 10 July 2020 is in line with both the original BMF letter of 6 November 2019 (BStBI I 2019, p. 1010) and the new BMF letter of 18 August 2020 and (continues to) apply without restriction."

###### **Berlin**

[Notification of 20 September 2020](https://www.berlin.de/sen/finanzen/presse/pressemitteilungen/pressemitteilung.995405.php)

"By way of clarification, it is pointed out that the Senate Department for Finance continues to grant Berlin businesses more time for the technical conversion of cash register systems due to Corona. However, this does not apply to taxpayers who have so far remained inactive or have already attracted negative attention. The General Order of 22 July 2020 published in the Official Gazette for Berlin OJ No. 32 / 31 July 2020, page 4141, continues to apply.

###### **Brandenburg**

[Brandenburg Message of 16 September 2020](/img/brandenburg_20200916_pm-mdfe-es-bleibt-dabei_frist-zur-umstellung-von-elektronischen-kassen-verlängert.pdf)

"According to the ministry, the ruling is in line with both the original BMF letter of 6 November 2019 and the more recent BMF letter of 18 August 2020 (BStBl. I 2020, p. 656)."

###### **Bremen**

In Bremen, a separate application is required by 30 September 2020. An individual application pursuant to Section 148 AO, which must be justified in detail, must be submitted to the competent tax office. According to our information, the need for a cloud TSS is sufficient to be classified as a hardship case, which leads to an extension of the deadline.

###### **Hamburg**

[Hamburg Message of 11 September 2020](/img/hamburg_schreiben-der-finanzbehörde-vom-11.09.2020-zur-tse-nichtbeanstandungsr.pdf)

"By way of clarification, I would like to point out that the decree of the Hamburg tax authority of 10 July 2020 (Ref. S 0319 - 2020 / 003 - 51) is consistent with both the original BMF letter of 6 November 2019 (BStBl. I 2019, p. 1010) and the more recent BMF letter of 18 August 2020 and (continues to) apply without restriction."

###### **Hesse**

[Notification of 14 September 2020](/img/hessen_mitteilung_des_hmf.pdf)

"By way of clarification, I would like to point out that the decree of the Hesse Ministry of Finance of 10 July 2020 is in line with both the original BMF letter of 6 November 2019 (BStBl I 2019, p. 1010) and the more recent BMF letter of 18 August 2020 and (continues to) apply without restriction."

###### **Mecklenburg-Vorpommern**

[Notification of 17 July 2020](https://www.regierung-mv.de/serviceassistent/_php/download.php?datei_id=1626158):

"In principle, it remains the case that the technically necessary adaptations and upgrades of the electronic recording systems must be carried out immediately, as far as possible, and the legal requirements must be met without delay. The evidence is to be kept with the procedural documentation for cash management in accordance with the general retention periods and presented on request.

###### **Lower Saxony**

[Supplementary information dated 11 September 2020](https://lstn.niedersachsen.de/steuer/steuermerkblaetter_und_broschueren/registrierkasse-tse-nachrustung-190754.html) on the website of the Lower Saxony State Tax Office.

"By way of clarification, I would like to point out that the requirements described in my [information letter of 10 July 2020](https://lstn.niedersachsen.de/download/157144) are in line with both the original BMF letter of 6 November 2019 (BStBl I 2019, p. 1010) and the more recent BMF letter of 18 August 2020 and - continue to be - valid without restriction."

###### **North Rhine-Westphalia**

[North Rhine-Westphalia Message dated 11 September 2020](/img/nordrhein-westfalen_el-übersendung-bmf-schreiben-bstbl-an-fä-2020_09_11_r.pdf)

"By way of clarification, I would like to point out that my decree of 10 July 2020 is consistent with both the original BMF letter of 6 November 2019 (BStBl I 2019, p. 1010) and the new BMF letter of 18 August 2020 and (continues to) apply without restriction."

###### **Rhineland-Palatinate**

Businesses in Rhineland-Palatinate will be given more time to equip electronic cash register systems with a certified technical security device (TSS).

###### **Saarland**

In response to our enquiry, we were informed that the Saarland still adheres to the decree. With reference to the following websites of the Ministry of Finance and Europe Saarland:

[Latest news: Saarland Message of 14 July 2020](https://www.saarland.de/mfe/DE/aktuelles/aktuelle-meldungen/medieninfo/2020/pm_2020-07-14-Kassensystem.html)

[FAQs on the topic: Upgrading cash register systems with a technical security device (TSS)](https://www.saarland.de/mfe/DE/aktuelles/aktuelle-meldungen/medieninfo/2020/pm_2020-07-21-TSE.html)

###### **Saxony**

The regulation continues to apply without restriction in Saxony. The associations, including the Chamber of Tax Consultants, were informed of this in an official letter on 16 September 2020.

###### **Saxony-Anhalt**

[Saxony-Anhalt Message of 18 September 2020](/img/sachsen-anhalt_20200918_festhalten_an_tse-verlängerung_st.pdf)

"By way of clarification, I would like to point out in this context that the decree of the Ministry of Finance of Saxony-Anhalt of 17 July 2020 is in line with both the original BMF letter of 6 November 2019 and the newer BMF letter of 18 August 2020 and (continues to) apply without restriction."

###### **Schleswig-Holstein**

In response to our enquiry, we were informed: The decree of the state of Schleswig-Holstein dated 10 July 2020 (VI 328 - S 0319 - 006, 36488/2020) does not contradict the BMF's view and therefore applies unchanged in Schleswig-Holstein.

###### **Thuringia**

[Thuringia Notification of 16 September 2020](/img/thüringen_p-fassung-tfm-erlass-vom-16.09.2020.pdf)

"By way of clarification, I would like to point out that the TFM decree of 23 July 2020 - S 0319 - 02 - 25.14, updated with today's date, does not contradict either the original BMF letter of 6 November 2019 (BStBl I 2019, p. 1010) or the more recent BMF letter of 18 August 2020, (continues to) apply without restriction and the previous procedure is to be adhered to."

The BMF has published a clarifying notice in September 2020, which once again refers to the deadline of 30 September 2020 for the non-compliance regulation.

Legal - New publication

rechtliches-nichtbeanstandungsregelung-zur-kassensichv-im-september-2020

In our last seminar, Johannes Ferner (CEO), Patrick Gaubatz (CTO) and Elias Priesching (BizDev Lead) spoke in detail about the system architecture of fiskaly SIGN DE. fiskaly SIGN DE is our fiscalisation solution (technical security system - TSS) for the German Kassensicherungsverordnung (KassenSichV).

Politicians and market participants are calling for more digitalization in Germany and thus also for the possibility of implementing the KassenSichV in a technology-neutral manner. fiskaly SIGN DE is a cloud-based and thus a distributed system. It has been certified by the Federal Office for Information Security (BSI) until 2029 on the basis of the specific requirements for such systems.

The architecture of our cloud-based TSS is significantly shaped by the legal requirements for a certified technical security system (TSS) as well as the implementation of distributed (POS) systems. In the thematic sections of the seminar, the structure of the system architecture, the certified operation as well as the environment protection of the Cloud TSS fiskaly SIGN DE were discussed. At the end, the speakers answered your questions in detail.

The seminar can be viewed on [our Youtube channel](https://www.youtube.com/watch?v=5PzS6aqFXkY).

[![fiskaly on YouTube](/img/sign-de-systemarchitektur-blogpost.webp)](https://www.youtube.com/watch?v=5PzS6aqFXkY)

In our last seminar, Johannes Ferner (CEO), Patrick Gaubatz (CTO) and Elias Priesching (BizDev Lead) spoke in detail about the system architecture of fiskaly SIGN DE.

In our last seminar, Johannes Ferner (CEO), Patrick Gaubatz (CTO) and Elias Priesching (Sales Lead) spoke in detail about the system architecture of fiskaly SIGN DE. The architecture of our cloud-based TSs is significantly shaped by the legal requirements for a certified technical security system (TSS) as well as the implementation of distributed (POS) systems.

Seminar Retro - fiskaly SIGN DE System Architecture

Seminar Retro fiskaly SIGN DE System Architecture

seminar-retro-fiskaly-sign-de-systemarchitektur

## In which data centre is the fiskaly Cloud data stored?

As required by the KassenSichV, the data may only be stored in Germany. fiskaly hosts and archives the data from the fiskaly cloud in Frankfurt am Main, in highly secure data centres. fiskaly meets all legal requirements and data protection guidelines that exist for this environment.
If you have any further questions, please do not hesitate to contact us: [sales@fiskaly.com](mailto:sales@fiskaly.com).

## Is there any more information about this?

We have compiled everything you need to know about fiskaly and the technical security equipment (TSE) on our [website fiskaly TSE](/en/kassensichv-tss-from-fiskaly), including the certifications of the data centres we use.

At fiskaly we deal with the topic of data protection and data security thoroughly, because our customers' data security is extremely important to us. All data is stored exclusively in Germany.

At fiskaly, we comprehensively deal with the topic of data protection and data security. All data is stored exclusively in Germany.

Server location in Germany.

Server location in Germany

serverstandort-deutschland

At fiskaly, we are revolutionizing the world of POS systems and uncovering tax fraud. fiskaly is the leading provider of cloud-based solutions in fiscalization in Germany and Austria. With SIGN DE, fiskaly creates the 100% legally compliant only cloud TSS on the market.

## The solution

The fiskaly SIGN DE cloud TSS is 100% software-based and can be integrated into all systems and cash register architectures. The integration is done quickly and easily by implementing the Rest API.

### The fiskaly Cloud TSS consists of two components:

* SMAERS component
* CSP-L component

These two components ensure the correct, encrypted capture and routing of transaction data, signing of transaction items and routing of data back to the respective POS system. In this way, the protection against manipulation in POS systems targeted by the [BSI](https://www.bsi.bund.de/EN/Home/home_node.html) is achieved. The system and the API can be tested free of charge in advance. [For that a Postman collection is available for a quick start](https://developer.fiskaly.com/api/kassensichv/v2#section/Quick-Start).

An additional service is the [fiskaly DSFinV-K](/en/dsfinv-k), which covers the export of data from electronic recording systems. The export of this data must be made available to the tax authorities via a standard digital interface on the occasion of an external audit or a cash inspection.

## Certified & legally compliant

[The fiskaly Cloud TSS and the related API of SIGN DE were certified on May 25, 2021](/en/articles/cloud-tss-certified). This means that the solution meets all the requirements of the KassenSichV, which was introduced in Germany on 26.09.2017. KassenSichV stipulates that from 30.09.2020 all cash registers in Germany whose design technically permits it must be equipped with a so-called technical security system (TSS). SIGN DE has the maximum certificate term until 2029 and is therefore the only certified cloud-based TSS for cash register systems in Germany. [The certificates can be viewed on our website](https://www.fiskaly.com/certificates).

## Advantages SIGN DE

SIGN DE brings our customers a wealth of benefits through its professionally developed software:

* 100% legally compliant and cloud-based
* fiskaly SIGN DE (+ fiskaly DSFinV-K) is cost-effective
* Fast integration into all POS systems through API
* Contract conclusion without annual commitment
* 1-Click rollout on all systems

Interested in fiskaly? [Take the first step to easy fiscalization now](/en/contact).

Information about SIGN DE, its certifications, legal compliance, and benefits can be found in this blog post.

fiskaly SIGN DE is our certified cloud TSS service in Germany. 100% compliant, SIGN DE revolutionizes the fiscalization industry.

SIGN DE - The cloud TSS for easy fiscalization

sign-de-die-cloud-tse-für-leichte-fiskalisierung

In the letter dated 21 August 2020, the Federal Ministry of Finance provides information on how the costs arising from the implementation of the certified technical security systems (TSS) are to be treated for tax purposes.

The following applies in the tax treatment of the costs of implementing TSS and the uniform digital interface:

## Cloud TSS
Ongoing charges incurred for cloud TSS are "regularly deductible immediately as business expenses"

## Hardware TSS
If a TSS consists of a USB stick, a memory card or similar, it is an independent asset that cannot be used independently. The acquisition costs must therefore be capitalised and depreciated over the normal useful life of three years.

If the TSS is installed as hardware directly in a cash register, it is not an independent asset. The expenses are therefore subsequent acquisition costs of the asset and are to be depreciated over its remaining useful life.

## Implementation costs
The expenses for the implementation of the TSS are incidental acquisition costs of the asset TSS.

## Simplification rule
In addition, there is a simplification rule, this states: 
"For simplification reasons, it is not objected if the costs for the subsequent initial equipment of existing cash registers or cash register systems with a TSS and the costs for the initial implementation of the uniform digital interface of an existing electronic recording system are immediately deducted in full as business expenses."

The letter of the BMF is available on the [website of the Federal Ministry of Finance](https://www.bundesfinanzministerium.de).

In its notice of 21 August 2020, the Federal Ministry of Finance provides information on how the costs arising from the first-time implementation of a technical security system (TSS) are to be treated for tax purposes.

In its notice of 21.08.2020, Federal Ministry of Finance informs how  to treat costs arising from the first-time implementation of TSS for tax purposes.

Modification of cash registers: What to consider when it comes to tax

umrüstung-von-kassen-was-bei-der-steuer-zu-beachten-ist

umrüstung-von-taxametern-und-wegstreckenzählern-was-bei-der-steuer-zu-beachten-ist

warum-sie-die-tse-signatur-im-qr-code-hinterlegen-sollten

webinar-“einfache-umsetzung-der-mitteilungspflicht-mit-fiskaly”

## What does the TSS CSP component do?
The central security component of the TSS (technical security device) is the CSP (Cryptographic Service Provider). This is the signature unit which processes the data to be secured accordingly using cryptographic procedures. This prevents undetected manipulation. In the signature process, SMAERS (Security Module Application for Electronic Record Keeping System) and CSP talk to each other via secure channels.

## Definition of CSP-L according to BSI
A CSP-L "ensures the integrity and authenticity as well as the completeness of the electronic record by applying cryptographic procedures." ([The CSP-L Protection Profile BSI-CC-PP-0111-2019](https://www.bsi.bund.de/SharedDocs/Zertifikate_CC/PP/aktuell/PP_0111.html).) Greatly simplified: a CSP-L is responsible for creating the signature via a document.

## fiskaly TSS CSP certified
The fiskaly TSE CSP-L is the high-performance signature unit that uses cryptographic methods to process the data to be secured accordingly. This prevents undetected manipulation. The specialised server systems are operated by fiskaly in highly secure data centers in Germany.

[Certification code BSI-DSZ-CC-1153-2021](https://www.bsi.bund.de/SharedDocs/Downloads/DE/BSI/Zertifizierung/Reporte/Reporte1100/1153a_pdf.pdf;jsessionid=E2CA372D750CF3B79256718D93DC5954.internet481?__blob=publicationFile&v=1)
![Certification Report BSI-DSZ-CC-1153-2021](/img/certification-report-bsi-dsz-cc-1153-2021.webp "Certification Report BSI-DSZ-CC-1153-2021")

## CSP and CSP-L
High-performance signature units are defined via the CSP-L protection profile. These are specialised server systems in highly secure data centers.

In contrast to the CSP-L, a CSP is usually a chip that cannot be operated efficiently in a network. A CSP chip is mainly suitable for single-user installations or "legacy" cash registers.

The network-capable variant of the CSP-L was developed with a special focus on scalability and efficiency, enabling, among other things, a higher data throughput and ensuring greater reliability.

Both variants are defined by protection profiles of the BSI (Federal Office for Information Security).
![TSE_SMAERS_CSP_Komponenten](/img/tse_smaers_csp_komponenten.webp)

### Further information:
[Protection Profile Cryptographic Service Provider Light (CSPL) — BSI-CC-PP-0111–2019](https://www.bsi.bund.de/SharedDocs/Zertifikate_CC/PP/aktuell/PP_0111.html)
[Protection Profile Cryptographic Service Provider Light — Time Stamp Service and Audit](https://www.bsi.bund.de/SharedDocs/Zertifikate_CC/PP/aktuell/PP_0112.html)
[Protection Profile Cryptographic Service Provider Light Time Stamp Service and Audit — Clustering](https://www.bsi.bund.de/SharedDocs/Zertifikate_CC/PP/aktuell/PP_0113.html)

This article introduces the TSS CSP components and what they do in the technical security system (TSS). 

What is the TSS CSP Component?

what-is-the-tss-csp-component

## Panel Discussion 'Fiscalisation'
At the panel discussion Fiscalisation we were pleased to welcome on the panel:

* Tobias Teutemacher - Tax Investigation Office - Finanzamt für Steuerstrafsachen und Steuerfahndung Münster.  
* Frank Schlesinger - Speaker IGZTK & CTO Orderbird AG
* Anne Rinkenberger - Auditor & Tax Consultant  
* Johannes Ferner - CEO fiskaly GmbH
* Moderated by Elias Priesching - fiskaly GmbH

You can also watch the recording of the panel discussion 'Fiscalisation' on our YouTube channel:

### **[Podium Discussion 'Fiscalisation' (in German)](https://www.youtube.com/watch?v=7V1mAA1ovrk&t=1s)**

The individual speeches as well as the discussion can be found as separate videos further down in this blog post.

## Summary:
**Tobias Teutemacher:**
* Difference recording system & input device: A mobile electronic recording system is an independent system that assigns invoice numbers, properly processes the input, stores it, autonomously calculates the VAT and prints the receipt. A mobile input or display device is only functional if the connection to the host system exists. 
* In 2015, the BFH clarified that a lack of certification according to TR-3153 is a formal defect. If it is a simple deficiency, with a low risk of tax default (i.e. everything has been documented and traceability is given), then the tax inspector is not entitled to carry out a tax assessment.

**Anne Rinkenberger:**
* The legal definition says an electronic recording system consists of a hardware and a software component. Since we can work in a technology-open way, this means that you can connect hardware or software. The connection between the ERS and the TSS can also be established without a hardware connection or local proximity: the legally required protection against manipulation is given. 
* The function and mode of operation required in § 146 AO is given with the fiskaly Cloud TSS, with a new and functional technology.

**Frank Schlesinger:**
* Customers automatically opt for manipulation protection with a cloud-based cash register system; fiskaly thus ends the "competitive disadvantages" of cloud cash registers. 
* The disillusionment with the design of the fiscalisation law led to the founding of igztk.de - an association of cash register manufacturers and partners who use cloud technologies. The igztk.de was able to educate the BMF and BSI and show that SMEs in particular use cloud technologies and that it is not a niche product;

**Johannes Ferner:**
* The fiskaly Cloud TSS can be put into operation as a certified Cloud TSS for purely cloud-based (complete EAS in cloud), for distributed systems (distributed EAS) and for on-premise POS systems (integration EAS via software).

## Expert opinion
The compliance of the TSS is already given by the extensive and so far longest certification of the fiskaly Cloud TSS. Due to various "market" voices, we have decided to have an additional expert opinion issued by a renowned auditing firm.
We will also clarify other issues openly, transparently and externally in the coming weeks!

### Expert opinion (Gutachterliche Stellungnahme)[![Gutachterliche Stellungnahme](/img/screenshot-from-2022-03-18-10-52-49.webp "Gutachterliche Stellungnahme")](/img/gutachterliche-stellungnahme.pdf)
At this point we would like to point out that the TSS certification is only valid including the complete conformity certificate and conformity report. In the context of full transparency, you will find these documents freely accessible on our websites.

### Certificate of conformity[![Konformitätsbescheid](/img/konformitätsbescheid-fiskaly.webp "Konformitätsbescheid")](/img/bsi-k-tr-0403-2021_tr-konformitaetsbericht_fiskaly.pdf)

### Conformity report
### [![Konformitätsreport](/img/konformitätsreport.webp "Konformitätsreport")](/img/BSI-K-TR-0403-2021_TR-Konformitaetsbericht_fiskaly_TSE-1705c4b9bf53a5fa36f734dbf9b2e7c2.pdf)Videos Speeches and discussion

#### [Tobias Teutemacher - Cash inspection 2021 (in YouTube)](https://youtu.be/65rQkJ6KLL8?list=PLAnY4fJEwmOvxWcYhqiS69DwSQCfNU48s&t=2)
[](https://www.youtube.com/watch?v=65rQkJ6KLL8)[](https://www.youtube.com/watch?v=65rQkJ6KLL8)Tax Investigation Office - Münster Tax Office for Criminal Tax Matters and Tax Investigation
Talks about what taxpayers can expect during a cash audit in 2021 and how they can best prepare for it.

#### [Frank Schlesinger - Fiscalisation from the perspective of a cash register manufacturer & integrator (in YouTube)](https://youtu.be/FbvB3GmKmoA?list=PLAnY4fJEwmOvxWcYhqiS69DwSQCfNU48s&t=4)
[](https://www.youtube.com/watch?v=FbvB3GmKmoA&t=335s)Frank Schlesinger - Speaker IGZTK & CTO Orderbird AG - gives an insight into orderbird's system and how the technology openness software-based cash register providers had to face due to the legal regulations.

#### [Anne Rinkenberger - Expert opinion (in YouTube)](https://www.youtube.com/watch?v=aepiH9E1a1g&list=PLAnY4fJEwmOvxWcYhqiS69DwSQCfNU48s&index=2)
[](https://www.youtube.com/watch?v=aepiH9E1a1g&list=PLAnY4fJEwmOvxWcYhqiS69DwSQCfNU48s&index=2)Anne Rinkenberger - Certified Public Accountant & Tax Advisor - talks about the approach to preparing the expert opinion for the Cloud TSS and which questions were relevant and in need of clarification.

#### [Johannes Ferner - Certified Cloud TSS fiskaly SIGN (in YouTube)](https://www.youtube.com/watch?v=4U4DjwslV-c&list=PLAnY4fJEwmOvxWcYhqiS69DwSQCfNU48s&index=5)
[](https://www.youtube.com/watch?v=4U4DjwslV-c&list=PLAnY4fJEwmOvxWcYhqiS69DwSQCfNU48s&index=5)Johannes Ferner - CEO fiskaly GmbH - gives an overview of the fiskaly system, the Cloud TSS and the legally compliant use of the fiskaly Cloud TSS.

#### [Discussion part (in YouTube)](https://www.youtube.com/watch?v=LkwQmmWRCMs&list=PLAnY4fJEwmOvxWcYhqiS69DwSQCfNU48s&index=8)
[](https://www.youtube.com/watch?v=LkwQmmWRCMs&list=PLAnY4fJEwmOvxWcYhqiS69DwSQCfNU48s&index=8)The discussion is all about the legally compliant use of the Cloud TSS and the legal framework when using a TSS in certification. How the tax authorities control the operation of the TSS and its environmental protection, as well as recommendations on how to proceed with applications under Section 148 AO and short deadlines.

fiskaly promotes open exchange between different stakeholders on the topic of fiscalisation. In this context, the panel discussion 'Fiscalisation' took place. Central topics: the legally compliant operation of a (cloud) TSS, compliance with relevant environmental protection topics and much more.

Central topics of panel discussion 'Fiscalisation' by fiskaly: legally compliant operation of a (cloud) TSS & relevant environmental protection topics.

Certified operation of the fiskaly Cloud TSS. Expert opinion

zertifizierter-betrieb-der-fiskaly-cloud-tse-gutachterliche-stellungnahme

## What is a protection profile?

The [BSI (Federal Office for Information Security) specifies in protection profiles](https://www.bsi.bund.de/EN/Themen/Unternehmen-und-Organisationen/Standards-und-Zertifizierung/Zertifizierung-und-Anerkennung/Zertifizierung-von-Produkten/Zertifizierung-nach-CC/Schutzprofile-Protection-Profiles-PP/schutzprofile-protection-profiles-pp_node.html) which technical requirements must be met in order to achieve the objective of the KassenSichV. The security profiles describe security objectives and requirements according to the security functions of the components. However, the product-specific specification is made by the manufacturer.
![tse_smaers_csp-schaubilder-zertifizierung](/img/tse_smaers_csp-schaubilder-zertifizierung-tse-1024x627.webp)

## How is the certification of the technical security system (TSS) carried out?

The CSP-L and the SMAERS components are certified independently of each other. In the process, the compliance of the components with the protection profiles is checked by an evaluator (a company accredited by the BSI). The evaluation report is then forwarded to the BSI for review. 

With a positive conclusion, the components each receive a certificate. Finally, the components in the network (= technical security system) are tested by the TR test. If the TSS is correct and implemented according to the applicable requirements, it is certified. 

When evaluating the SMAERS component, there are strong synergies with the TR test, i.e. the TR test can only be passed positively if the SMAERS component has also been positively evaluated. Therefore, after receiving the SMAERS certificate, the final TSS certification can be expected soon. The BSI issues the certification, which must be renewed every five years.

The requirements for the components SMAERS and CSP are specified by the BSI in protection profiles. Compliance with the requirements for each component is ensured in the course of certification.

Requirements for SMAERS and CSP are specified by BSI in protection profiles. Compliance with requirements for each component is ensured during certification.

How does the BSI certification of the technical security system (TSS) work?

zertifizierung-der-tse

Paragraph 146 AO establishes the key requirements for bookkeeping and recordkeeping to ensure transparency and traceability. These regulations are essential to prevent data manipulation and ensure the proper recording of financial transactions.
## The core requirements of paragraph 146 AO
### Individual recordkeeping and traceability
According to Paragraph 146 (1) AO, all bookings and records must be made individually, completely, accurately, promptly, and in an organized manner. This forms the basis for seamless documentation, particularly in cash register systems. An exception to the individual recordkeeping obligation applies only when goods are sold to a large number of unknown customers for cash—unless an electronic recording system as defined in Paragraph 146a AO is used.
### Data integrity: protection against manipulation
A key requirement of Paragraph 146 (4) AO is the immutability of records. Changes to records must not obscure their original content, and every modification must be clearly traceable. For cash register systems, this necessitates tamper-proof technology such as a [Technical Security Systems (TSS)](https://kassensichv.net/en/cloud-tss).
### Data retention and availability
Data stored on digital media must, according to Paragraph 146 (5) AO, be readily accessible and legible at all times. These requirements are particularly relevant for digital and cloud-based solutions, which allow companies to manage their data efficiently while ensuring legal compliance.
## Paragraph 146 AO as the basis for specific requirements: the link to paragraph 146a AO
While Paragraph 146 AO provides the overarching legal framework, Paragraph 146a AO defines the specific requirements for electronic recording systems used in cash registers. The two paragraphs are closely connected: Paragraph 146 AO outlines the general recordkeeping rules, while Paragraph 146a AO specifies the technical and organizational measures required for cash register systems.
## Paragraph 146a AO: the obligation to record cash transactions tamper-proof
To enhance transparency and traceability in cash register systems, Paragraph 146a AO of the German Tax Code (AO) mandates the use of electronic recording systems that securely record every cash transaction. For companies and cash register providers, this primarily means one thing: their systems must meet the highest security standards and ensure that no retrospective changes to the data are possible.
In the following section, we explain what Paragraph 146a AO entails, how these requirements are implemented, and why [fiskaly's Cloud TSS SIGN DE](https://www.fiskaly.com/signde) offers a particularly effective solution.
## § 146a AO and its detailed requirements
According to § 146a AO, clear organizational requirements for bookkeeping apply. All fiscally relevant cash transactions must be recorded using an electronic system protected against tampering. While this entails strict record-keeping obligations for cash register providers and their customers, it also brings benefits: compliance with the principles of proper accounting and enhanced transparency and security.
### Individual recording obligation per § 146a AO sentence 1
Under § 146a AO Sentence 1, electronic recording systems must capture every transaction individually, completely, and accurately. This so-called individual recording obligation is mandatory for cash register systems and ensures the seamless traceability of all transactions.
For example, every receipt generated is immediately stored in the electronic recording system, preventing tampering and ensuring comprehensive traceability—an essential advantage during tax audits [or cash inspections](https://kassensichv.net/en/articles/cash-inspection-kassennachschau-in-germany-what-merchants-should-know).
### Receipt issuance obligation: transparency for customers
Sentence 2 of § 146a AO establishes the [receipt issuance obligation](https://kassensichv.net/en/articles/receipt-issuance-obligation-in-germany-background-effects-and-alternatives). Businesses recording transactions are required to issue a receipt for each transaction. This issuance must occur promptly in connection with the transaction.
In certain cases—such as sales to a large number of unknown customers—the tax authority may grant exceptions, which, however, can be revoked.
### Technical security system (TSS): protection against tampering
One of the core requirements of § 146a AO (Sentence 3) is equipping electronic recording systems with a certified technical security system (TSS). This ensures that all recordings are tamper-proof and verifiable at any time.

fiskaly offers an innovative [Cloud TSS](https://kassensichv.net/en/kassensichv-advantages-of-cloud-tss) solution with the following advantages:
* **Flexible Use:** No hardware required, ideal for growing businesses.
* **Simple Integration:** Compatible with existing cash register systems.
* **Centralized Management:** Manage all systems via a single platform.
* **Cost Efficiency:** No additional hardware acquisition costs.
### Notification obligations per § 146a AO
Businesses using electronic recording systems must comply with [notification obligations](https://kassensichv.net/en/articles/new-reporting-obligations-2025-cash-registers-taximeters-odometers) under § 146a AO (Sentence 4) to the tax authority. The following information must be reported:
* Name and tax ID of the taxpayer,
* Type of certified technical security device,
* Type of electronic recording system used,
* Serial numbers and acquisition or decommissioning data.

The notification must be submitted within one month of the system's acquisition or decommissioning. This requirement ensures that the tax authority maintains oversight of the systems in use.
## Benefits of fiskaly's cloud TSS
Adhering to § 146a AO regulations and implementing a certified TSS offer businesses legal certainty and operational advantages.
### Key benefits at a glance:
1.  **Legal Certainty:** Avoid penalties and issues during audits through tamper-proof records.
2. **Efficiency:** Centralized management saves time and reduces maintenance effort.
3. **Sustainability:** Cloud solutions conserve resources and reduce paper usage.
With fiskaly, taxpayers can manage all electronic records in an organized and compliant manner. Businesses benefit from a flexible, modern, and scalable solution that enhances efficiency and security in the long term.
## Conclusion: security and transparency with fiskaly
Paragraph 146 AO forms the foundation for the digitalization and security of cash register systems. Its clearly defined recordkeeping rules ensure that tax-relevant processes remain transparent and traceable.
Paragraph 146a AO represents a significant step toward the digitalization and security of cash register systems in Germany. The requirements for a certified Technical Security Device (TSS) build trust and transparency while contributing to fair taxation.
With fiskaly's Cloud TSS, cash register providers have a powerful solution at their disposal that is easy to implement and meets the highest legal standards.
## Application decrees for § 146a AO
The Federal Ministry of Finance (BMF) has issued important application decrees related to § 146a AO:
* [BMF Letter of June 30, 2023](https://www.bundesfinanzministerium.de/Content/DE/Downloads/BMF_Schreiben/Weitere_Steuerthemen/Abgabenordnung/AO-Anwendungserlass/2023-06-30-AEAO-Par-146-AO.pdf?__blob=publicationFile&v=2): Specifies requirements for electronic recording systems, particularly for taximeters and odometers.
Read the decree
* [BMF Letter of June 28, 2024](https://www.bundesfinanzministerium.de/Content/DE/Downloads/BMF_Schreiben/Weitere_Steuerthemen/Abgabenordnung/2024-06-28-mitteilungsverpflichtung-nach-AO.html): Details notification obligations, such as reporting TSE data to the tax authority.


Germany’s Paragraphs 146 and 146a AO define key rules for transparent bookkeeping and secure cash register systems. This blog explains their purpose and how fiskaly's Cloud TSS simplifies compliance with these regulations. Discover how modern technology supports legal and efficient operations for businesses of all sizes.

Take the next step

Understand Germany's Paragraphs 146 and 146a AO, the rules for secure cash registers, and how fiskaly helps businesses meet legal standards efficiently.

Germany's Paragraphs 146 and 146a AO: Recordkeeping Made Secure

Germany's paragraph 146 and 146a AO: guidelines for cash register compliance

§-146-ao-und-§-146a-ao-ordnungsvorschriften-für-kassensysteme-verständlich-erklärt

The law for the protection against manipulation of basic digital records came into force at the end of December 2016 and stipulates that a Technical Security Device (TSS) is to be developed for all cash register systems within three years. The TSS is certified by the Federal Office for Information Security (BSI). Until 30 September 2020, the Federal Ministry of Finance (BMF) grants a non-objection regulation.

## Decrees of the Federal States 

In July, 15 federal states extended deadlines for upgrading cash register systems with a TSS under certain conditions by decree. In the federal states, the regulations vary as to when an extended deadline is granted. This applies, among other things, to the time of the binding order of the TSS, the proof of non-availability as well as the use of a cloud-based TSS. As of 31.03.2021, stationary or cloud-based TSS solutions must be installed in the cash registers in all federal states. We recommend that the requirements be recorded by means of suitable documentation and retained for the statutory retention period. A self-documentation is not sufficient. The note from the Non-objection regulation of 06.11.2019 "Adjustments and upgrades must be carried out immediately and the legal requirements must be fulfilled without delay" still applies. 

![Short overview of the decrees of the federal states on the KassenSichV.](/img/kurzübersicht-zu-den-erlassen-der-bundesländer-zur-kassensichv.webp "Short overview of the decrees of the federal states on the KassenSichV.")

## The regulations in detail:

### Baden-Württemberg

**Requirement for a stationary or a cloud-based** TSS **solution:** 

Proof that it was not possible to equip the electronic cash register systems with TSS by 30.09.2020 and that a binding order or contract was placed before 01.10.2020.

**Is an application to the tax office necessary?** 

No

**[Notification of 13.07.2020](https://fm.baden-wuerttemberg.de/de/service/presse-und-oeffentlichkeitsarbeit/pressemitteilung/pid/frist-zur-umruestung-auf-manipulationssichere-kassen-verlaengert/)**

### Bavaria

**Requirement for a stationary** TSS **solution:** 

Proof of binding order of the required number of TSSs from a specialist cash register dealer or other service provider by 30.09.2020.

**Prerequisite for a cloud-based TSS solution:** 

Proof of the order of a cloud-based TSS or proof that the installation of such is planned but not yet available.

**Is an application to the tax office necessary?** 

No

**Other requirements**: 

The requirements must be demonstrated by appropriate documentation and retained for the duration of the statutory retention period.

### Berlin

**Requirement for a stationary or a cloud-based TSS solution:** 

The installation of a TSS must have been commissioned by 30.08.2020 with a specific date. Confirmation by companies carrying out the installation of the TSS that the conversion is not possible by 30.09.2020.

**Is an application to the tax office necessary?** 

No

**Other requirements:** 

All obligations according to the Tax Code (§146a) must be fulfilled. For the assessment period 2010 to 2020, there are no criminal or administrative offence proceedings for tax evasion/tax jeopardy that have been concluded with a conviction, a penalty order, a condition or a penalty notice.

[Announcement of 24.07.2020](https://www.berlin.de/sen/finanzen/presse/pressemitteilungen/pressemitteilung.965025.php)

### Brandenburg

**Prerequisite for a stationary or a cloud-based TSS solution:** 

The installation was commissioned by 31.08.2020 and the commissioned company confirmed that the installation could not be carried out by 30.09.2020. In addition, a specific installation date has been agreed.

**Is an application to the tax office necessary?** 

No

**Other requirements:** 

The voucher requirement is fulfilled. For the assessment period 2010 to 2020, there are no criminal or administrative offence proceedings for tax evasion/tax jeopardy that have been concluded with a conviction, a penalty order, a condition or a penalty notice. The prerequisites must be proven by means of suitable documentation and retained for the duration of the statutory retention period.

### Bremen

In Bremen, a separate application is currently necessary. An individual application in accordance with § 148 AO, which must be justified in detail, must be submitted to the responsible tax office. According to our information, the need for a cloud TSS is sufficient to be classified as a hardship case, which leads to an extension of the deadline.

### Hamburg

**Prerequisite for a stationary TSS solution:** 

Proof of a binding order for the required number of TSSs from a specialist cash register dealer, cash register manufacturer or other service provider by 30 September 2020.

**Prerequisite for a cloud-based TSS solution:** 

If a cloud-based TSS is planned but not yet available, the unavailability must be proven by appropriate documents. The deployment must be ensured by 31.03.2021.

**Is an application to the tax office necessary?** 

No

**Further requirements:** 

The requirements must be proven by suitable documentation, must be maintained for the duration of the statutory retention period and must be presented upon request.

### Hesse

**Requirement for a stationary TSS solution:** 

Proof of a binding order for the required number of TSSs from a specialist cash register dealer, cash register manufacturer or other service provider by 30.09.2020.

**Prerequisite for a cloud-based TSS solution:** 

If a cloud-based TSS is to be provided, but such a TSS is not yet available, the non-availability must be proven by appropriate documents.

**Is an application to the tax office necessary?** 

No

**Other requirements:** 

Required evidence must be kept by the taxpayer within the general retention periods and presented to the tax authorities upon request.

### Mecklenburg-Western Pomerania

**Requirement for a stationary TSS solution:** 

Proof of a binding order for the required number of TSSs from a specialist cash register dealer, cash register manufacturer or other service provider by 30 September 2020.

**Requirement for a cloud-based TSS solution:** 

Proof of binding order by 30.09.2020 and timely deployment of the cloud-based TSS.

**Is an application to the tax office necessary?** 

No

**Other requirements:** 

The evidence must be kept with the procedural documentation for cash management in accordance with the general retention periods and must be presented on request.

[Notification of 17.07.2020](https://www.regierung-mv.de/serviceassistent/_php/download.php?datei_id=1626158)

### Lower Saxony

**Requirement for a stationary TSS solution:** 

Proof of binding order for the required number of TSSs from a cash register dealer, cash register manufacturer or other service provider by 31.08.2020. As well as proof that installation is not possible by 30.09.2020.

**Prerequisite for a cloud-based TSS solution:** 

The installation of a cloud-based TSS is planned, but such a solution is demonstrably not yet available.

**Is an application to the tax office necessary?** 

No

**Other requirements:** 

Retention of the supporting documents confirming the hardship is sufficient.

[Notification of 10.07.2020](https://www.mf.niedersachsen.de/startseite/aktuelles/presseinformationen/niedersachsen-hessen-bayern-nordrhein-westfallen-und-hamburg-pragmatische-und-unburokratische-losung-bei-kassensystemen-190646.html)

### North Rhine-Westphalia

**Requirement for a stationary TSS solution:** 

Proof of a binding order for the required number of TSSs from a cash register dealer, cash register manufacturer or other service provider by 30.09.2020.

**Prerequisite for a cloud-based TSS solution:** 

If a cloud-based TSS is to be provided for, but such a TSS is not yet available, the non-availability must be proven by means of suitable documents.

**Is an application to the tax office necessary?** 

No

**Other requirements:** 

The evidence must be kept with the procedural documentation for cash management in accordance with the general retention periods and must be presented on request.

[Notification of 10.07.2020](https://www.finanzverwaltung.nrw.de/sites/default/files/asset/document/el_2020_07_10.pdf)

### Rhineland-Palatinate

**Prerequisite for a stationary TSS solution:** 

The installation was commissioned by 31.08.2020 and the commissioned company confirms that the installation could not be carried out by 30.09.2020.

**Prerequisite for a cloud-based TSS solution:** 

The installation of a cloud-based TSS is planned

**Is an application to the tax office necessary?** 

Yes

### Saarland

**Prerequisite for a stationary or cloud-based TSS solution:** 

Proof of a binding order for the installation or a cloud-based solution from a cash register dealer, cash register manufacturer or other service provider before 30.09.2020.

**Is an application to the tax office necessary?** 

No

[Notification of 14.07.2020](https://www.saarland.de/mfe/DE/aktuelles/aktuelle-meldungen/medieninfo/2020/pm_2020-07-14-Kassensystem.html)

### Saxony

**Requirement for a stationary TSS solution:** 

Proof of commissioning of the installation of a TSS by 31.08.2020

**Prerequisite for a cloud-based TSS solution:** 

Proof of commissioning the installation of a cloud-based TSS by 31.08.2020 and proof that it is not yet available.

**Is an application to the tax office necessary?** 

No

[Notification of 15.07.2020](https://www.medienservice.sachsen.de/medien/news/238805)

### Saxony-Anhalt

**Prerequisite for a stationary or a cloud-based TSS solution:** 

Proof of commissioning of the timely installation of a TSS by 30.09.2020

**Is an application to the tax office necessary?** 

No

Information from enquiry to press office

### Schleswig-Holstein

**Prerequisite for a stationary or cloud-based TSS solution:** 

Proof of commissioning of the timely installation of a TSS by 30.09.2020 from a specialist cash register dealer, a cash register manufacturer or another service provider in the cash register sector.

**Prerequisite for a cloud-based TSS solution:** 

In the case of a planned deployment of a cloud-based TSS, companies must have demonstrably commissioned the timely deployment by 30 September 2020 at the latest.

**Is an application to the tax office necessary?** 

No

**Other requirements:**

The evidence must be kept with the procedural documentation for cash management in accordance with the general retention periods and must be presented on request.

[Meldung vom 10.07.2020](https://www.stbvsh.de/static/content/e3/e23645/e124828/e133039/downloads2/download/ger/SH-Erlass_Verl%C3%A4ngerung%20Frist%20TSE-Einsatz%20bis%203_21.pdf)

### Thuringia

**Requirement for a stationary TSS solution:** 

Proof of binding commissioning of the required number of TSSs from a specialist cash register dealer, a cash register manufacturer or another service provider in the cash register area by 30.09.2020.

**Prerequisite for a cloud-based TSS solution:** 

The installation of a cloud-based TSS is planned.

**Is an application to the tax office necessary?** 

A separate application is not required for this, the existence of one of these prerequisites must simply be declared to the tax office. This can be done informally or [using a form](https://finanzen.thueringen.de/fileadmin/user_upload/Finanzaemter/Vordrucke/anzeige_zeitl__erleichterungen_148_146a_ao.pdf), which can be downloaded from the website of the Thuringian Ministry of Finance.

KassenSichV and the ordinances of the federal states: How can you continue to work in compliance with the law from 1 October 2020? 

Overview of the ordinances of all federal states on KassenSichV

übersicht-der-erlasse-aller-bundesländer-zur-kassensichv

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