Ever­ything about cer­ti­fi­ca­ti­on and TSS

Which TSS is cer­ti­fied? Which TSS can I obtain to con­ti­nue to work in com­pli­an­ce with the law from 1.10.2020?

Elias Priesching

Elias Prie­sching

Sales Mana­ger

The Kas­sen­SichV has offi­cial­ly come into force since 1.1.2020. Up to now, a dif­fe­ren­tia­ted pic­tu­re of the inten­si­ty with which cash regis­ter manu­fac­tu­rers have dealt with the topic has emer­ged. Howe­ver, this will change abrupt­ly on 1.10.2020. From this date, every POS system must be equip­ped with a TSS (basic infor­ma­ti­on on this can be found here).

As a cash regis­ter manu­fac­tu­rer the ques­ti­on arises: Which TSS solu­ti­on do I use? Legal con­for­mi­ty is often the decisi­ve cri­ter­ion. The problem:

No TSS is cur­r­ent­ly fully cer­ti­fied — only pro­vi­sio­nal­ly released!

So what can cash regis­ter manu­fac­tu­rers do?

Tech­ni­cal secu­ri­ty system (TSS) cus­to­mers basi­cal­ly have the pos­si­bi­li­ty to inte­gra­te cloud tech­ni­cal secu­ri­ty sys­tems or hard­ware tech­ni­cal secu­ri­ty sys­tems. This results in huge dif­fe­ren­ces in terms of cer­ti­fi­ca­ti­on, range of ser­vices, prac­ti­ca­bi­li­ty and costs. We would like to go into this in more detail below.

The cur­rent situation

Some hard­ware TSS ven­dors have a tem­pora­ry clearan­ce for their sys­tems and the­re­fo­re need to be recer­ti­fied by the end of 2020 at the latest. Howe­ver, there are major risks invol­ved — for examp­le, upgrading to a new pro­tec­tion pro­fi­le. Tech­ni­cal secu­ri­ty sys­tems with a tem­pora­ry release are de facto only par­ti­al­ly tested and the­re­fo­re there is a risk that no final cer­ti­fi­ca­ti­on can be achie­ved. This would cause several problems:

  • The TSS manu­fac­tu­rer would have to be re-cer­ti­fied at the end of 2020. If the re-cer­ti­fi­ca­ti­on is not com­ple­ted posi­tively, a new TSS solu­ti­on must be found.  In the worst case, the cus­to­mers would have to find a new supplier.
  • If the re-cer­ti­fi­ca­ti­on reve­als major short­co­mings in the TSS, it could lead to a com­ple­te ban on ope­ra­ti­ons des­pi­te the cur­rent pro­vi­sio­nal release. This would mean that all tech­ni­cal secu­ri­ty sys­tems which are alrea­dy in ope­ra­ti­on would have to be replaced.

What are the consequences?

It is pos­si­ble that all hard­ware tech­ni­cal secu­ri­ty sys­tems (TSS) would have to be repla­ced com­ple­te­ly. Hard­ware solu­ti­ons are very cost-inten­si­ve to purcha­se and pose enor­mous logisti­cal chal­len­ges. So if chan­ges ever have to be made, all hard­ware tech­ni­cal secu­ri­ty sys­tems would poten­ti­al­ly have to be com­ple­te­ly repla­ced. This would lead to repeated costs and roll-out chal­len­ges. Fur­ther­mo­re, hard­ware tech­ni­cal secu­ri­ty sys­tems cannot keep up with the per­for­mance spec­trum of cloud solu­ti­ons around the necessa­ry processes.

The cer­ti­fi­ca­ti­on of a cloud TSS is only a ques­ti­on of time. There are POS sys­tems where it is tech­ni­cal­ly impos­si­ble to install a hard­ware com­po­nent (e.g. based on RDP — Remote Desk­top Pro­to­col). Tech­ni­cal secu­ri­ty sys­tems as cloud solu­ti­ons are also offi­cial­ly cer­ti­fied by the BSI (see FAQ BSI. Unfor­tu­n­a­te­ly, this FAQ is only avail­ab­le in German. If you have any ques­ti­ons, you can the­re­fo­re con­ta­ct us at any time. We can help you in any lan­guage). The lea­ding pro­vi­der of cloud tech­ni­cal secu­ri­ty sys­tems is fis­ka­ly, due to its tech­no­lo­gi­cal advan­ta­ge and unique range of ser­vices. “The beauty of a cloud solu­ti­on is its sim­pli­ci­ty com­bi­ned with end­less pos­si­bi­li­ties”, docu­ments Dr. Patrick Gau­batz, TSS expert at fiskaly.

Our recom­men­da­ti­on is quite clear, a cloud TSS with which all (legal) requi­re­ments can be reac­ted to quick­ly and chea­ply. For examp­le, a fur­ther post­po­ne­ment of the no objec­tion rule. If there should ever be any legal chan­ges or other updates, you can inte­gra­te them cen­tral­ly in a cloud solu­ti­on and have the issue solved. With a hard­ware solu­ti­on, you liter­al­ly have to handle each PoS indi­vi­du­al­ly. The cloud solu­ti­on from fis­ka­ly goes far beyond the actual signa­tu­re unit! While hard­ware is purely the signing unit, the cloud solu­ti­on from fis­ka­ly offers inno­va­ti­ve added value for the cus­to­mer (eRe­ce­i­pt, DSFinV‑K, dash­board for the admi­nis­tra­ti­on of all TSSs, acti­va­ti­on at the tax office, SSO, multi-client capa­bi­li­ty, …) and is also more cost-effec­ti­ve — con­ta­ct fis­ka­ly at sales@fiskaly.com.