Reporting obligation 2025: Cash register reporting to the tax office

Hannah Roegele

Product Marketing Manager

12/30/20246 min read

Hannah has been with fiskaly for more than 3 years. With her in-depth knowledge of the extensive fiskaly product portfolio, she excels at simplifying complex technical concepts.

The Cash Register Security Ordinance (KassenSichV) is a key legal framework in Germany aimed at preventing manipulation of electronic cash register systems and enhancing transaction transparency. Since January 1, 2020, it requires all electronic cash systems to be equipped with a certified Technical Security Device (TSS).

A major component of the KassenSichV is the reporting obligation, mandating businesses to register their cash systems with the tax office to ensure compliance with the ordinance.

New regulations for electronic recording systems will take effect on January 1, 2025, applying to both cash registers and EU taximeters and odometers. This article covers the importance of cash register reporting, required data, and efficient implementation.

What is cash register reporting?

Cash register reporting is a requirement under the KassenSichV, obligating businesses to register their electronic cash systems with the appropriate tax office. By providing this information, tax authorities gain insights into the number and status of the deployed cash register systems even before audits take place, significantly simplifying the on-site inspection process. This increases transparency and reduces the risk of tax fraud.

According to Section 146a of the German Fiscal Code (AO) and KassenSichV, all electronic recording systems, including their TSS, must be reported. The goal is to prevent manipulation, ensuring a transparent foundation for tax control. The reporting process is conducted securely via the ELSTER portal using the ERIC interface (Elster Rich Client) or automatically via the fiskaly SIGN DE x Submission API.

Registration must occur before the cash system's initial use. Additionally, businesses are required to report subsequent changes, such as system decommissioning or TSS replacement, to ensure tax authorities have up-to-date information.

Who is affected by the reporting obligation?

The cash register reporting obligation applies to all companies using electronic recording systems. This includes electronic or computer-based cash registers and point-of-sale systems. It also covers EU taximeters, odometers (see changes to the application decree for the Tax Code under § 146a), and businesses like pharmacies.

What are the deadlines for the reporting obligation, and what changes in 2025?

With the new regulations taking effect, the BMF letter dated November 6, 2019, will be fully repealed. From January 1, 2025, all businesses in Germany will be required to register their electronic cash register systems with the tax office. The aim of this regulation is to enhance transparency and traceability in the use of such systems and to prevent tax evasion.

Deadlines for 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.

Deadlines for 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 TSS before July 1, 2025, must be reported by July 31, 2025.
Systems acquired or equipped with a TSS 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.

What information must be reported?

As part of the cash register reporting process, businesses are required to transmit a variety of information about the cash register systems and TSS (Technical Security System) used at each business location to the tax office. Details are specified in § 146a (4) Sentence 2 of the German Fiscal Code (AO):

Type of cash register system: Description of the system used (e.g., stationary register, mobile system, cloud-based system).
System serial number: Unique identifier for each cash register.
Details of the TSS: Serial number, certificate number, manufacturer, and type.
Date of commissioning: When the system was first used.
Location: Address where the cash register is used.
Change information: Decommissioning, replacement, or updates to the TSS.

These details ensure the tax office has a comprehensive overview of the systems in use and can detect potential manipulations.

How must the data be reported?

The reporting to the tax office must be submitted electronically. The data from the electronic cash register system is manually transmitted via the ELSTER portal using the ERIC interface. fiskaly, in collaboration with the Hessian tax administration, conducted a pilot project to test the practical implementation of automated cash register data reporting. Together with three partners, the first reports were successfully completed, confirming the functionality and reliability of the solution. The insights gained from this project were directly incorporated into the development of the SIGN DE x Submission API.

You want to ensure automated and legally compliant cash register reporting?

The fiskaly SIGN DE x Submission API replaces manual electronic submissions via the ELSTER portal, offering time and cost savings through easy integration and process optimization. The development of the API for the automated transmission of cash register data to tax authorities in accordance with §146a (4) AO is based on our successful pilot project with the Hessian tax administration. fiskaly acts purely as an IT service provider, offering technical infrastructure to simplify the process for businesses without engaging in data validation or tax consulting.

The fiskaly SIGN DE x Submission API offers numerous advantages:

Automation: The API enables nearly automatic submission of cash register data, significantly reducing manual effort.
Efficiency: Businesses save time and costs through seamless integration with existing cash register systems.
Compliance: The solution ensures that all legal requirements under Section 146a AO are met.

What are the deadlines and consequences of non-compliance?

Non-compliance with the cash register notification obligation can have significant legal and financial consequences for companies: fines of up to €25,000 (§379 AO), tax disadvantages due to estimates by the tax office, as well as more intensive audits of bookkeeping, since unregistered cash register systems are considered potentially susceptible to manipulation. Additionally, criminal consequences may follow if tax fraud is proven. Subsequent registration and retrofitting of cash register systems involve additional effort and costs, which can impair operational efficiency.

Tips for simplifying the implementation of cash register reporting obligations

Address the reporting obligations early and plan integration: Start planning and implementing the new requirements early to avoid bottlenecks or delays.
Ensure timely reporting: Make sure that cash register systems are registered before they are put into operation, and that changes, such as decommissioning or replacing the TSS, are reported on time.
Use the Submission API: Leverage the fiskaly SIGN DE x Submission API to automate and ensure compliance in your cash register reporting. The API minimizes manual effort, saves time, and ensures that all requirements under Section 146a AO are met.

Conclusion

The new reporting obligations for electronic recording systems represent a significant change that businesses should address promptly. By reporting systems on time, companies can ensure compliance with the new legal requirements and avoid potential penalties. The earlier you address the implementation of reporting obligations, the easier it will be to integrate them into your existing processes. Use the fiskaly SIGN DE Submission API to streamline the process and prevent delays.

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