Sweden: XML export from journal memory becomes mandatory from 1 January 2027

From 1 January 2027, every cash register in Sweden must meet SKVFS 2021:17. For registers with journal memory, this means registrations must be exportable to an XML file valid against the Swedish Tax Agency’s schema. The rules date from 2021; what ends now is the transitional period.

The Swedish Tax Agency (Skatteverket) states on its cash register page that, from 1 January 2027, a business’s cash register must comply with the Agency’s regulation on cash register requirements, SKVFS 2021:17. The same page states that if the cash register has a so-called journal memory, it must be able to produce registrations in XML format.

This is not a new law. The underlying regulations were adopted on 22 November 2021 and entered into force on 1 January 2022. The transition was set in two steps. Manufacturers could apply the earlier provisions when manufacturing cash registers only until 31 December 2022, while businesses have been allowed to keep using registers that record data under the earlier requirements until 31 December 2026. It is this second period that now ends.

Journal memory and control roll

A Swedish cash register must record not only sales but also other use of the register, such as opening the cash drawer without a sale, returns, receipt copies, reports and user log-ins. This record can be kept on paper, as a control roll (kontrollremsa), or electronically, as a journal memory (journalminne).

Journal memory should not be confused with the control unit. The control unit, or the software-based control system, receives receipt data from the register and generates control codes, while the journal memory is the record kept in the cash register itself. The XML export requirement concerns the journal memory.

What the export must contain

The standardised export is regulated by SKVFS 2021:16. For each registration unit, the register must be able to retrieve the registrations made in the journal memory for different time periods and export them to a file in XML format. The file must follow the XML 1.0 specification, use UTF-8 encoding and be valid against the schema published in Skatteverket’s schema repository. A completeness rule applies in both directions: data covered by the regulation that the register has recorded must be included, and data the register records beyond that scope must not be included.

The file starts with introductory elements: the register from which the export is made, the time of export, the selected start and end of the period, the selected registers, company details (organisation or personal identity number, company name and the address where sales take place) and the cash register system, including the manufacturing numbers of the register and of the control unit or control system. Each registration then carries common elements, such as the register designation and the time of registration, and the export covers a wide range of events:

• items: registration, change and deletion of items, as well as parked items;
• cash drawer and input: opening the drawer without a sale, clearing, price enquiries and change of float;
• documents: receipts, return receipts, receipt copies, pro forma receipts and training receipts;
• reports: X reports, Z reports and other reports;
• operation of the register: start, stop, restart, log-in, log-out, clock adjustment and switching to and from training mode;
• the control system: status codes and the verification (reconciliation) of receipt data between the control program and the control server.

The schema

Skatteverket publishes the schema in its XML schema repository (Schemalager) as “Xml-schema för tillverkning av kassaregister”, together with an explanatory document and a document with element examples. According to the explanatory document, the package contains an instance schema named after SKVFS 2021:16 and dated 8 December 2021, plus component schemas. Element names are in Swedish and often long, so mapping should be done directly against the schema.

Who is responsible

Responsibility is shared. The manufacturer or supplier confirms in the manufacturer’s declaration (tillverkardeklaration, SKV 1509) that the cash register meets Skatteverket’s requirements, and must submit a new declaration when a version update affects functions covered by the regulation. The business using the register is responsible for ensuring that the register it uses meets the requirements. Skatteverket can impose a control fee of SEK 12,500 if it finds deficiencies during an inspection visit, and SEK 25,000 if a new violation occurs within one year.

In our view

The deadline itself is clear, but several points deserve attention. First, the XML requirement is linked to journal memory. Registers that keep only a paper control roll have no journal memory, and in our reading the export requirement does not apply to them; we have not found an explicit exemption, so this remains an interpretation. Second, the export covers many non-sales events, such as log-ins, restarts, clock adjustments and training mode. A register that does not record these events in its journal memory today has a gap that goes beyond the export function itself. Third, Skatteverket’s page highlights the XML export, but SKVFS 2021:17 amends the cash register requirements more broadly, so vendors should review the full amended text rather than the export alone.

What should businesses do?

With less than three months to go, the practical steps are:

• Ask the cash register supplier whether the register has journal memory and, if so, whether it supports the XML export under SKVFS 2021:16.
• Ensure that the export can be produced for each registration unit and for different time periods.
• Validate sample exports against the current schema from Skatteverket’s Schemalager, including non-sales events and control system codes.
• Check that the manufacturer’s declaration (SKV 1509) reflects the current requirements and that the model appears on Skatteverket’s list of declared cash registers.
• Avoid confirming compliance to end customers until schema validation has been successfully completed.

This article is based on information published by Skatteverket on its cash register pages, the XML schema repository and its explanatory documents, and on SKVFS 2021:16, SKVFS 2021:17 and SKVFS 2021:18. Source Source Source

Aleksandra Vukić, Business Analyst at Fiscal Solutions

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