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Certified operation of the fiskaly Cloud TSS. Expert opinion.

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)

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


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

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 conformityKonformitätsbescheid

Conformity report

KonformitätsreportVideos Speeches and discussion

Tobias Teutemacher - Cash inspection 2021 (in YouTube)

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)

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)

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)

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)

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.