1 Background
Since 1 January 2025, operators of electronic recording systems have been required to notify the tax authorities to this effect. This is based on sec. 146a para. 4 of the German Fiscal Code (AO), in conjunction with the Cash Register Security Regulation (KassenSichV). The aim is to create more transparency and control in the area of cash recording. The notification must be made via the official platform ‘Mein ELSTER’ or a correspondingly connected software solution. The Federal Ministry of Finance specified the requirements in a letter dated 28 June 2024.
2 Who is affected?
The obligation applies to all businesses that use electronic or computerised cash register systems or cash registers with a certified technical security device (TSE). These include:
- Electronic cash registers and cash register systems
- Cloud-based cash register software
- Cash register apps for smartphones and tablets
- Mobile cash register systems
- Cash register systems integrated into ERP and inventory management systems
- EU taximeters and odometers with cash register function
- Billing software with cash register function (e.g. for medical practices and mobile service providers)
Rented or leased systems are also subject to the reporting obligation.
3 What must be reported?
The notification to the tax office must be made electronically via ELSTER and must contain the following information:
- Name and tax number of the taxpayer
- Company name
- Type of electronic recording system used (e.g. app cash register, cloud solution)
- Number of electronic recording systems per business location
- Serial number of the electronic recording system used
- Type of certified technical security device (cloud or hardware TSE)
- Date of purchase of the electronic recording system used
- Date of decommissioning of the electronic recording system used
- Special case of taximeters/odometers: The vehicle registration number of the vehicle concerned must also be provided.
4 What are the deadlines?
Existing devices purchased before 1 July 2025 must be reported by 31 July 2025, at the latest. New devices purchased on or after 1 July 2025 must be reported within one month of purchase.
5 Challenge: technical connection to ELSTER
The notification must be submitted electronically via the ERiC interface (ELSTER Rich Client) – either directly via ‘Mein ELSTER’ or via third-party software that integrates ERiC. This poses a challenge for many companies, as cash register systems or ERP solutions must be adapted to the complex XML specifications and security requirements. Manual entry via the ELSTER portal is possible, but not very practical for multiple systems in branch structures.
6 What happens in the event of violations?
It is not entirely irrelevant to ask what consequences companies can expect if they fail to comply with their reporting obligations or do so late. A fine, pursuant to sec. 379 AO, is not provided for in the event of a breach of the reporting obligation under sec. 146a para. 4 AO (unlike the other obligations for cash registers under sec. 146a AO). Only a penalty payment, pursuant to sec. 328 et seq. AO, can be imposed. However, failure to report could of course also be seen as an indication of manipulation, which could, in turn, trigger unannounced cash register spot checks or more intensive tax audits.
7 What should you do now?
Given the short time remaining until 31 July 2025, companies that have not yet notified the tax authorities of their existing systems and do not yet have a process in place for new acquisitions, should urgently ensure that their reports can be submitted correctly, in terms of both content and form. An early test notification via ELSTER can help to avoid errors and prevent missed deadlines. Please do not hesitate to contact us if we can support you with our expertise.
Contact:
Certified Tax Consultant, Dipl.-Finanzwirt (FH)
Phone: +49 89 217501250
As per: 28.07.2025
