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

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

### SMAERS Certificate

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

### TR-Certificate

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

### ![](/img/logo-igztk.png) 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-.png)
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 sub-organisation.

## Organisations and user rights
In the fiskaly system, a distinction is made between main organisations and sub-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. Sub-organisations (in the fiskaly system: managed organizations) can be attached to them. Sub-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 sub-organisations.

**Important: A main organisation cannot be a sub-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 sub-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.png "fiskaly user rights")

### What is a sub-organisation?
The sub-organisation is dependent on its superior main organisation and can never stand alone. It must always be subordinate to a main organisation. Sub-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.png "create organisation")

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

### How to create a sub-organisation (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 sub-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.png "create managed organisation")

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

### Difference in user rights in main and sub-organisations
Users of main organisations or sub-organisations have access to the information displayed in the dashboard of the respective organisation. The user rights within the main organisation and the sub-organisation differ in that users of the main organisation also have access to the information of the respective linked sub-organisations. Users of the sub-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.png "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.png "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 sub-organisations. A separate API key must be created for each sub-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 sub-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 sub-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 sub-organisations can be created with the live API key, so that each sub-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.png "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 sub-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.png "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.jpg "Organisational structure")

**1. Individual customers - best practice**
Under the main organization of the cash register manufacturer, individual customers are created and managed as sub-organizations. The main organization is used to create the respective API Key of the sub-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 sub-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 sub-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 (sub-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.png "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-bridging-aid-iii-%C3%BCberbr%C3%BCckungshilfe-iii#:~:text=through%20%C2%A7146a%20AO.-,Where%20can%20bridging%20assistance%20III%20be%20applied%20for%3F,-Tax%20advisors%2C%20auditors)).

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](https://www.tentaworks.com/)** - 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

## 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. The translation is not legally binding. \[Link zur Übersetzung auf developer.fiskaly.com]

##### **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 product 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

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

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

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

### Environmental protection concept
### [![Umgebungsschutz](/img/umgebungsschutz.png "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

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.

## 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/receiptsen.png "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 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) 28.04.20212. [Bundesrat Drucksache 438/21](https://www.bundesrat.de/SharedDocs/drucksachen/2021/0401-0500/438-21.pdf?__blob=publicationFile&v=1) 21.05.20213. [Bundesrat Drucksache 438/1/21](https://www.bundesrat.de/SharedDocs/drucksachen/2021/0401-0500/438-1-21.pdf?__blob=publicationFile&v=1) 14.06.20214. [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

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 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](/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 the SIGN DE product, fiskaly creates the 100% legally compliant only cloud TSS on the market.

## The product

The fiskaly SIGN DE cloud TSS is 100% software-based and can be integrated into all systems and cash register architectures. The integration of the product 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](https://kassensichv.net/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](https://kassensichv.net/en/articles/cloud-tss-certified). This means that the product 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). The product 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

The SIGN DE product 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 of the product into all POS systems through API
* Contract conclusion without annual commitment
* 1-Click rollout on all systems

Our product has aroused your interest in fiskaly? [Take the first step to easy fiscalization now](https://kassensichv.net/en/contact).

Information about SIGN DE, its certifications and legal compliance, as well as benefits of the product can be found in this blog post.

fiskaly SIGN DE is our certified cloud TSS product 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/Content/DE/Downloads/BMF_Schreiben/Weitere_Steuerthemen/Abgabenordnung/2020-08-21-steuerliche-behandlung-der-kosten-der-erstmaligen-implementierung-einer-zertifizierten-technischen-sicherheitseinrichtung.pdf?__blob=publicationFile&v=2).

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

## 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.png "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.jpg)

### 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.png "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.png "Konformitätsbescheid")](/img/bsi-k-tr-0403-2021_tr-konformitaetsbericht_fiskaly.pdf)

### Conformity report
### [![Konformitätsreport](/img/konformitätsreport.png "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 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.png)

## 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

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](https://www.bundesfinanzministerium.de/Content/DE/Downloads/BMF_Schreiben/Weitere_Steuerthemen/Abgabenordnung/2019-11-05-nichtbeanstandungsregelung-bei-verwendung-elektronischer-aufzeichnungssysteme.pdf?__blob=publicationFile&v=2) "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.png "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.

[Message of 10.07.2020](https://www.stmfh.bayern.de/steuern/aufzeichnungssysteme/Nichtbeanstandungsregelung.pdf)

### 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.

[Notification of 10.07.2020](https://stbk-hamburg.de/wp-content/uploads/HH-Nichtbeanstandungsregelung-TSE.pdf)

### 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? 