Reporting obligation for cash register systems, taximeters and other electronic recording systems

From 2025, the tax authorities will provide the long-planned transmission option for reporting electronic recording systems, which means that the previously suspended reporting obligation will come into force from July 2025.

The reform of the legal requirements for cash register systems and other electronic recording systems through the "Act on Protection against Manipulation of Basic Digital Records" not only stipulated the installation of a TSE (technical security device) for most such devices and systems, but also stipulated that entrepreneurs must report their cash registers and other recording systems to the tax office. For many years, this reporting obligation was suspended and therefore did not need to be observed because the tax authorities were unable to provide the necessary electronic reporting procedures in time. This will change from 2025, as the corresponding electronic transmission options are to be available from January 1, 2025.

The reporting obligation affects all electronic recording systems for the recording of business transactions and other cash transactions that must be recorded. This includes in particular

• Cash registers and electronic cash register systems

• Software-based recording systems for checkout processes (app solutions for tablets or smartphones as well as industry software with checkout function or checkout module, e.g. for medical practices or hotels)

• Scales with cash register function

• Merchandise management systems with checkout function

• EU taximeter and odometer

There are currently three alternatives available to businesses for reporting. In addition to direct entry in the "Notification of electronic recording systems" form on the ELSTER website or uploading an XML file created by the POS system or recording software to the ELSTER website, the POS systems or other software packages can also use the ERIC interface to make the notification directly. If the system or software used supports this function, this should be the most convenient alternative. The entrepreneur can make the declaration himself or have it made by the tax consultant or the manufacturer or supplier of the POS system.

All electronic recording systems of a permanent establishment must always be included in the report for each transmission. The tax office requires a total of seven mandatory details in the report:

1. Name of the company or entrepreneur

2. Tax number of the company

3. Type of certified technical safety device

4. Type of electronic recording system used

5. Number of electronic recording systems used

6. Serial number(s) of the recording system(s) used

7. Date of acquisition or decommissioning of the electronic recording system

The report must be submitted no later than one month after the acquisition or decommissioning of an electronic recording system. However, this requirement only applies from July 1, 2025, although the reporting option will be available from January 1, 2025. Accordingly, recording systems acquired before July 1, 2025 must be reported by July 31, 2025 at the latest.

Recording systems that were permanently decommissioned before July 1, 2025 and are no longer present in the business do not have to be reported unless their acquisition has already been reported beforehand. Rented or leased devices as well as rental and exchange devices are to be treated as purchased recording systems and must therefore also be included in a report.

Even if, as things stand at present, failure to comply with the reporting obligation is not an administrative offense and therefore there is no immediate threat of a fine if the report is not made or not made on time, compliance with the reporting obligation is advisable. The tax office is more likely to "pick out" those businesses for closer inspection or a cash register inspection that are particularly sloppy in their compliance with the reporting obligation. The tax office can also impose a penalty payment or other coercive measures to enforce reporting. Finally, it is also possible that the legislator could change the legal situation at any time and upgrade the failure to report to an administrative offense. If you don't keep a constant eye on changes to the law and quickly catch up with the notification, you may be threatened with a hefty fine that you can't simply talk your way out of.