fiskaly’s statement on the coalition agreement of April 9, 2025

What does the new coalition agreement stipulate regarding cash register systems?

The coalition agreement between CDU, CSU, and SPD stipulates that starting January 1, 2027, businesses with an annual turnover exceeding 100,000 euros will be required to use cash registers (“Registrierkassenpflicht”). At the same time, the current obligation to issue receipts – known as the “Belegausgabepflicht” – is to be abolished. So far, no details are known about the abolition of the receipt requirement: it is unclear whether this will apply only to certain industries, transaction amounts, etc., or whether the requirement will be abolished altogether.

How does fiskaly evaluate the introduction of the”Registrierkassenpflicht”?

Background: KassenSichV in Germany – Tamper-Proof Recording Systems

Germany introduced its fiscalization system in 2020 via the “Kassensicherungsverordnung” (KassenSichV). It consists of various pillars to guarantee a secure audit trail:

• TSE: The regulation mandates that all cash register systems must be equipped with a certified Technical Security Device (TSE). The TSE records every transaction in a tamper-proof manner and generates a digital signature to prevent manipulation. These signed transaction data must be stored and made available for audits by the tax authorities.

• DSFinV-K format: Transaction data must be recorded in the standardized DSFinV-K format (Digital Interface of the Tax Administration for Cash Register Systems). This facilitates the review and analysis of data during tax audits. This standard ensures that all cash register data is complete, traceable, and verifiable.

• Receipt issuance requirement: Businesses are required to issue a receipt for every transaction, regardless of the payment method. This ensures that all sales are captured and correctly reported.

• Reporting obligation: As of January 2025, all businesses operating in Germany must report electronic recording systems (cash registers, EU taximeters, and distance recorders) and TSE details to the tax office.

The next step in fiscalization:

fiskaly welcomes all measures aimed at increasing transparency, tax fairness, and competition. The "Registrierkassenpflicht", together with a certified TSE, is a long-overdue step in combating tax evasion and strengthening the legal economy. As a provider of cloud-based fiscalization solutions, we see this as a significant step forward on the path to a digital and trustworthy tax infrastructure.

What is problematic about abolishing the receipt issuance requirement?

While the TSE ensures tamper-proof recording of each transaction, without a receipt, there is no immediate control mechanism. Neither clients nor audit authorities can verify if a transaction was properly recorded – businesses could simply conduct transactions outside the cash register system. Receipt issuance is a central element in the fiscal audit trail. If it is abolished, it creates a dangerous loophole that opens the door to manipulation.

What is fiskaly’s position?

The "Registrierkassenpflicht" must necessarily be combined with a receipt issuance requirement - ideally in digital form. Exceptions can be introduced for specific cases. A commonly cited criticism of the receipt requirement is the inconvenience: Why issue a receipt for every small purchase? Many receipts end up unread in the trash – creating unnecessary paper waste and putting a strain on the environment and small businesses. This criticism is understandable. However, it must not be forgotten that the receipt plays a crucial role in the fiscal control process. It is the only immediately visible proof that a transaction was actually recorded – for both customers and audit authorities. The solution, therefore, is not to abolish the requirement but to modernize it: With digital receipts – e.g., via QR code, app, or email – transparency is maintained while customers can freely choose whether and in what form they wish to receive the receipt.

We understand the political goal of relieving small businesses and reducing paper waste. However, we believe that eliminating the receipt issuance breaks the entire audit trail of the fiscalization system.

Therefore, we propose:

• Ensuring no loopholes are created that allow transactions to bypass the system.

• Maintaining a technology-neutral implementation of the receipt requirement, e.g., via QR code, app, or email—there are already plenty of solutions on the market that avoid the paper issue while still ensuring that transactions are properly recorded in the audit system.