How do you pre­pa­re for an unex­pec­ted cash regis­ter audit — Kas­sen­nach­schau?

The fact that a cash regis­ter audit does not have to be announ­ced makes many entre­pre­neurs anxious. We tell you ever­ything you need to know on the topic and advise you how to get pre­pa­red for it.

Simon Tragatschnig

Simon Tra­gatsch­nig

Unter­neh­mer, Finanz & Tech­nik-Exper­te

Since 1 Janu­a­ry 2018, the tax aut­ho­ri­ties have been aut­ho­ri­zed to carry out cash-regis­ter audits (Kas­sen­nach­schau­en) in com­pa­nies. The finan­ci­al offi­cers will, the­re­fo­re, check the regu­la­ri­ty of cash manage­ment. If the audi­tor finds any incon­sis­ten­ci­es, it could lead to pen­al­ties and even to exter­nal audit. We’ll exp­lain what you need to pre­pa­re for a poten­ti­al Kas­sen­nach­schau.

Who is tar­ge­ted by this cash regis­ter audit — Kas­sen­nach­schau?

Every com­pa­ny which has an elec­tro­nic or open cash regis­ter in ope­ra­ti­on must be sub­ject to Kas­sen­nach­schau. Espe­ci­al­ly the indus­tries which inten­si­ve­ly ope­ra­te with cash are tar­ge­ted by the finan­ci­al aut­ho­ri­ties. Among these are:

  • hair­dres­sers
  • restau­rants (and rela­ted gas­tro­no­mic busi­nes­ses)
  • taxi com­pa­nies
  • gas sta­ti­ons
  • phar­maci­es
  • bake­ries
  • and other types of busi­nes­ses that invol­ve cash pay­ments.

Inci­dent­al­ly, Ger­ma­ny is one of the last European coun­tries to intro­du­ce the so-called fis­ca­li­za­ti­on of cash regis­ters. In many other coun­tries, simi­lar regu­la­ti­ons have been in force for years. In Aus­tria, a simi­lar regu­la­ti­on came into force in 2017.

How exac­t­ly does a cash regis­ter audit take place?

First­ly, you need to know that the cash regis­ter audit is not syn­ony­mous with a search war­rant. The finan­ci­al audi­tors have per­mis­si­on to check only your cash regis­ter system. It is important that you, as a tax­pay­er, know in advan­ce how this audit would take place. Only then you can pre­pa­re ever­ything pro­per­ly.

Our tip: Check right now, if all data is com­ple­te­ly and cor­rec­t­ly recor­ded in your cash regis­ter!

This is how the audit pro­cess usual­ly runs:

  • An audi­tor can come by at any time unan­noun­ced and in plain clo­thes. Howe­ver, the audit will only take place on the com­mer­ci­al pro­per­ty of the tax­pay­er and during normal working hours. Ent­e­ring the living space is only an option if public safety and order were in urgent danger.

  • The audi­tor will iden­ti­fy him­s­elf with a ser­vice card. Only then is the audi­tor ent­it­led to start the audit of your cash regis­ter system.

  • the cash regis­ter audit can also take place in the absence of the entre­pre­neur. This means that the audi­tor may even requi­re your employees to pro­vi­de the data. Note: accord­ing to the BMF, this can only be requested from employees who have all the essen­ti­al rights of access and use of the taxpayer’s cash regis­ter system.

  • the audi­tor must be gran­ted access to the cash regis­ter. The finan­ci­al offi­cer will tho­rough­ly check the bil­ling sys­tems and the records. He is also allo­wed to take pic­tures or scan the docu­ments.

Addi­tio­nal requi­re­ments accord­ing to Kas­sen­SichV

In the future, the proper use of record­ing sys­tems accord­ing to Kas­sen­SichV § 146a Abs 1 AO will be also che­cked in the con­text of the cash regis­ter audit. This regu­la­ti­on will come into effect after Decem­ber 31, 2019. From then on, entre­pre­neurs are requi­red to have a tech­ni­cal secu­ri­ty system (TSS) inte­gra­ted into their record­ing system.

If you use an elec­tro­nic cash regis­ter system, the audi­tor is aut­ho­ri­zed to request you to hand over cash regis­ter records and boo­kings of reve­nues and expen­ses, through a stan­dard digi­tal inter­face. He is also ent­it­led to request you to pro­vi­de the data on a data medium that can be eva­lua­ted by auto­ma­tic means. This also app­lies only after 31 Decem­ber 2019.

Pre­pa­ra­ti­on for the Kas­sen­nach­schau

In order to be opti­mal­ly pre­pa­red for the cash regis­ter audit, you can ask yours­elf the fol­lo­wing ques­ti­ons and find out what the pos­si­ble weak points are:

  • Does your cash regis­ter meet the tech­ni­cal requi­re­ments?

Check as soon as pos­si­ble, if your cash regis­ter meets the tax requi­re­ments.

  • Are all busi­ness cases recor­ded?

You should make sure that all employees comply with the legal mea­su­res.

  • Reve­nues & Expen­ses — is the dif­fe­rence noti­ce­ab­le bet­ween these in your cash regis­ter system?

Your pri­cing system must show the reve­nue and expen­ses in a clear­ly dis­tin­guis­ha­ble form.

  • Do you have the pos­si­bi­li­ty to send the records in elec­tro­nic format?

You need to be always able to hand over your data to the Finanz­amt (finan­ci­al aut­ho­ri­ties).

  • Are the even­tu­al chan­ges docu­men­ted?

If a change of the records in your cash regis­ter system cannot be avoi­ded, make sure this is trans­pa­rent and veri­fia­ble.

No-wor­ries audit

The Kas­sen­nach­schau will no longer worry you if you choose an opti­mal cash regis­ter system. Espe­ci­al­ly the fol­lo­wing func­tions are the ones that can make your life easier:

  • the docu­ments of the cash regis­ter can be made avail­ab­le easily and at any time
  • the system allows the trans­fer of the data in an elec­tro­nic format accep­ted by the finan­ce aut­ho­ri­ties (Finanz­amt).

Do you have any ques­ti­ons? We are here for you!