Germany: Mandatory Electronic Cash Registers and Digital Receipts Proposed from 2028

Germany plans to require electronic cash-register systems for larger businesses from January 1, 2028, while replacing automatic paper receipts with electronic receipt availability. The Second Cash Register Act has Cabinet approval but must still pass the legislative process.

Germany is preparing a major change to its cash-register rules. On September 23, 2026, the Federal Cabinet approved the draft Second Cash Register Act (Zweites Kassengesetz), which would introduce a general electronic cash-register requirement for businesses above a specified turnover threshold and make digital receipts the standard from January 1, 2028.

The proposal is particularly relevant to retailers, restaurants, cafés and other cash-intensive businesses that still use an open cash box (offene Ladenkasse) rather than an electronic recording system. According to the Federal Ministry of Finance (BMF), around 115,000 open cash boxes are still used in Germany.

The measures are not yet enacted law. Cabinet approval means that the draft can proceed through Germany’s legislative process, during which the provisions may still be amended.

Under the Cabinet-approved draft, businesses with total annual turnover exceeding EUR 100,000 would generally be required to use an electronic cash-register system from January 1, 2028. The change would substantially limit the continued use of traditional open cash boxes by larger businesses.

Businesses with annual cash sales below EUR 12,000 would be excluded from the new cash-register obligation. The draft would also authorise the Ministry of Finance to introduce additional exemptions by regulation. The Ministry identifies possible cases such as trust-based cash boxes, direct agricultural sales and weekly or annual markets.

These additional exemptions are therefore not final exemptions written into the current rule. Their precise scope would need to be established through subsequent regulations.

Where an electronic cash register becomes mandatory, the system would need to comply with the existing requirements of Section 146a of the German Fiscal Code (Abgabenordnung – AO).

This means that transaction records must be protected by a certified Technical Security Device (Technische Sicherheitseinrichtung – TSE). The system must also generate records according to DSFinV-K, the digital interface used by the German tax authorities for cash-register data.

Germany is therefore not introducing an entirely new technical fiscalization model. Instead, the proposal expands the group of businesses that would be required to use the secure electronic cash-register framework that already applies when qualifying electronic recording systems are used.

The second major change concerns the receipt process.

Germany currently requires businesses using electronic recording systems to make a receipt available for transactions. Under the proposed reform, the automatic issuance of a paper receipt would be replaced from January 1, 2028, by an obligation to make an electronic receipt available.

This does not abolish the receipt requirement.

The retailer would still have to provide access to a receipt, but the standard method would become electronic. The Federal Government gives examples such as a QR code displayed at the checkout, a download link or provision through a customer account. Customers would not be required to download or otherwise accept the electronic receipt. A paper receipt could still be provided where the customer requests one.

For POS providers, this creates a practical distinction between receipt generation and receipt delivery. The transaction must still result in the required receipt data, but automatically printing that receipt on paper would no longer be the default process.

Retail systems may therefore need functionality for presenting or transmitting an electronic receipt while retaining the possibility of paper output where requested.

The Second Cash Register Act also contains stronger measures against manipulation of electronic transaction records.

The draft introduces a new tax criminal offence concerning the use and distribution of manipulation software for electronic recording systems. It would also create administrative offences for failing to make the required receipt available and, where the new cash-register obligation applies, for failing to use an electronic recording system protected by a TSE.

The investigative powers of the Tax Authorities would also be expanded. In particular, the authorities would receive additional powers in cases involving the falsification of technical records where electronic recording systems covered by the Cash Register Security Ordinance are involved.

Another proposed change concerns rental cars. The scope of Section 146a AO would be extended by requiring rental cars to use distance-measuring devices equipped with a digital interface capable of connecting to a TSE. The BMF explains that this would align the treatment of rental cars with taxis.

Impact on retailers and POS providers

For retailers already operating compliant TSE-protected electronic cash registers, the new cash-register obligation itself may have limited impact. Their more immediate implementation issue could be the move from automatically printed receipts to digital receipt availability.

The larger change concerns businesses that still operate open cash boxes and exceed the proposed EUR 100,000 annual turnover threshold. These businesses would need to move to an electronic system meeting Section 146a AO requirements, including TSE protection and DSFinV-K-compatible records.

For POS software providers, the proposal therefore affects both sides of the checkout process. Systems may need to support customers migrating from non-electronic cash recording, while existing POS solutions will need to ensure that digital receipt delivery can become the normal process from 2028.

The exact implementation should not yet be treated as fixed. The draft must pass through Parliament, and further rules may define additional exemptions and practical requirements.

What should businesses prepare for?

Businesses currently using an open cash box should first determine whether their annual turnover would place them above the proposed EUR 100,000 threshold and whether the EUR 12,000 cash-sales exemption could apply.

Retailers expecting to fall within the mandatory electronic cash-register requirement should review whether they already use, or would need to acquire, a system compliant with Section 146a AO, TSE and DSFinV-K requirements.

Businesses already using electronic POS systems should focus particularly on the proposed receipt change. POS providers and retailers should review how electronic receipts could be made available at checkout and how paper receipts can continue to be issued when requested.

From a retail fiscalization perspective, the proposal does more than require businesses to replace an open cash box with a digital device. It connects secure transaction recording, standardized audit data and electronic receipt delivery within the same checkout process. The practical implementation issue will therefore be whether retailers can move to digital receipts without weakening receipt availability or creating unnecessary friction at the POS.

The principal source is the German Federal Ministry of Finance, which published the Second Cash Register Act proposals following Cabinet approval on September 23, 2026. Source

Ivana Picajkić, Medior Legal Consultant at Fiscal Solutions

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