Germany is facing a major change in cash register management. On September 23, 2026, the Federal Cabinet approved the draft bill on the further development of cash register records. On November 6, 2026, the German Bundestag debated the draft bill in its first reading. It was then referred to the committees for further deliberation; the Finance Committee is in charge of the matter.
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This marks an important step forward in the legislative process. So far, there have been no changes to the key provisions of the government’s draft bill: The plan calls for mandatory use of cash registers for businesses with total sales exceeding 100,000 euros, an exemption for those with less than 12,000 euros in annual cash sales, and a transition to electronic receipt issuance starting in 2028.
First, it’s important to note: There is still no general requirement in Germany to use an electronic cash register. Businesses are generally still permitted to use a traditional cash register, but they must comply with existing tax record-keeping and documentation requirements.
The bill is now available as Bundestag Document 21/8867. Following the first reading on November 6, 2026, the relevant committees are now deliberating on the bill. During this process, changes may still be made to individual provisions, thresholds, transition periods, or exemptions.
The Bundesrat is also scheduled to consider the government’s draft bill on November 20, 2026. The bill requires the approval of the Bundesrat, meaning that the states will also play an important role in the subsequent proceedings.
The requirement to enroll in a health insurance plan starting in 2028 is therefore still planned, but has not yet been finalized. The following information reflects the current status of the government’s draft bill from November 2026.
According to the current government draft, the cash register requirement would generally apply if the total revenue, as defined in Section 19(2) of the Value-Added Tax Act (UStG), exceeds 100,000 euros in a calendar year. It is important to note that this refers not only to cash or register sales, but to the company’s total revenue as defined for tax purposes.
The draft bill already provides for one important exception: Businesses that accept cash payments but have annual cash sales of less than 12,000 euros will not be subject to the new cash register requirement.
For many retailers who already use a modern electronic point-of-sale system, this is unlikely to change much at first. Anyone who uses an electronic point-of-sale system with cash register functionality must already comply with existing requirements regarding the certified technical security device (TSE) and Section 146a of the German Fiscal Code (AO). The planned sales thresholds do not override these existing requirements.
The new regulations are scheduled to take effect in 2028. For individual retailers, however, the key factor is when the relevant requirements are first met.
According to the current government draft, the following graduated scale is proposed:
In each case, this is subject to none of the specified exceptions applying. The government’s draft bill stipulates that, for a first-time violation beginning in 2027, the requirement to use a cash register will take effect on July 1 of the following year. Federal Ministry of Finance
If a company subsequently falls permanently below the applicable requirements again, the obligation to participate in the health insurance system is to end, according to the government’s draft bill, at the end of the second consecutive calendar year in which the requirements are no longer met.
Electronic point-of-sale systems have long been widespread in the German retail sector. According to the federal government, however, there are still approximately 115,000 manual cash registers in use. With these, sales are not recorded by an electronic system.
This is exactly where the planned mandatory use of cash registers comes into play. Electronic point-of-sale systems that comply with the requirements of Section 146a of the German Fiscal Code (AO) protect their basic records using a certified technical security device (TSE) and generate data in accordance with DSFinV-K, the tax administration’s digital interface for point-of-sale systems. This is intended to make manipulation more difficult and ensure that business transactions are more easily traceable for tax audits.
At the same time, the law is intended to reduce bureaucracy in other areas. In its assessment of the draft bill, the National Regulatory Review Board estimates that the annual compliance costs for the business sector as a whole could be reduced by approximately 106 million euros. This is offset by an estimated one-time transition cost of approximately 99 million euros. A significant portion of the expected reduction in administrative burden stems from the planned transition from paper documents to digital documents.
In addition to the threshold of less than 12,000 euros in cash sales, the bill provides for the possibility of further exemptions. The Federal Ministry of Finance cites, among other things, cash-only sales at agricultural businesses, direct sales on farms, and weekly and annual markets as possible scenarios where the exemption would apply.
However, caution is advised here: A blanket exemption for certain industries has not yet been finalized. The details are to be set forth in a separate regulatory ordinance, which so far exists only as a draft for discussion.
This distinction is particularly important for farm stands and direct sellers. In the current draft for discussion, for example, while revenue from a trust fund does not have to be recorded directly through an electronic cash register, it must subsequently be recorded on a regular basis in an electronic record-keeping system. Similar rules for subsequent recording are also provided for temporary or mobile sales outlets.
A statement such as “Farm stands are exempt from the requirement to have a cash register” would therefore be incorrect at this time.
Digital receipts are already permitted. Under current law, a receipt may be issued in paper form or—with the recipient’s consent—electronically in a standardized data format. Providing an electronic receipt via a QR code and a download also satisfies the current requirement to issue a receipt.
Starting January 1, 2028, this principle is set to change: According to the government’s draft bill, an electronic receipt in a standardized data format must generally be provided. The specific method of delivery remains technology-neutral. Possible options include, for example, a QR code, a download link, NFC, email, or delivery to a customer account. The customer is not required to actually retrieve or accept the digital receipt.
At the express request of customers, paper receipts will continue to be available. In the future, digital receipts will be the standard, and paper receipts will be the exception.
A special transitional provision is in place for certain point-of-sale systems with a weighing function that are also subject to measurement and calibration regulations. These systems will be permitted to continue issuing paper receipts instead of electronic receipts until December 31, 2032. This is intended to prevent a situation where, due to differing legal requirements, both a paper receipt and an electronic receipt must be issued for the same business transaction.
This issue therefore affects not only merchants who will need an electronic cash register for the first time in the future. Businesses that already use a TSE-compliant cash register should also assess how their cash register solution will be able to implement the planned electronic receipt provision in the future.
The planned requirement to use a cash register should not be confused with the existing regulations.
Anyone who currently uses an electronic point-of-sale system with the corresponding cash register functionality must comply with the applicable legal requirements. These include, in particular, securing the system with a certified TSE, as well as the legal requirements for record-keeping and receipt issuance. In addition, there is already a requirement to report electronic record-keeping systems to the tax authorities.
The current draft bill calls for expanding this reporting requirement starting in 2028. In the future, if only the certified TSE is replaced without changing the actual point-of-sale system, this TSE replacement must also be reported to the tax authorities. The report must be submitted within one month of the replacement.
The new cash register requirement therefore does not mean that the basic requirements for electronic cash register systems will not take effect until 2028. Rather, what is new is that certain businesses will be required to use an appropriate electronic cash register system in the future.
The government’s draft bill provides for additional penalties. Anyone who fails to use a required electronic recording system with a certified TSE despite being subject to the cash register requirement will be deemed to have committed an administrative offense. The current draft bill provides for a fine of up to 25,000 euros for such an offense.
Even if a required electronic receipt is not provided, is provided incorrectly, or is not provided on time, it should be possible to penalize this as an administrative offense in the future.
In addition, the regulations governing tampering software for electronic point-of-sale systems will be significantly tightened. The draft bill establishes a separate criminal offense for the commercial distribution of such tampering programs and their use. Penalties could include a fine or imprisonment for up to three years.
It is therefore important for merchants to verify in a timely manner whether their point-of-sale system meets the legal requirements. Since the legislative process has not yet been completed, these penalty provisions are, for the time being, based on the provisions outlined in the government’s draft bill.
The government’s draft bill also provides for new sanctions. Among other things, violations of the requirement to provide electronic receipts, as well as the unauthorized failure to use a mandated electronic recording system with TSE, would be punishable as administrative offenses. In addition, the use or distribution of tampering software would be subject to stricter criminal penalties.
It is therefore important for merchants to check in a timely manner whether their point-of-sale system meets the legal requirements.
There is still no reason to replace hardware in the short term because of the proposed bill. However, businesses that have been using open cash registers up to now should assess their situation early on.
The following questions are particularly relevant:
This makes it possible to identify early on whether and when action might be needed.
Example 1: Retailer with an open cash register
A retailer will exceed the applicable total sales threshold as early as 2026 and generate significantly more than 12,000 euros in cash sales. Unless another exemption applies, the retailer would be required to use a compliant electronic cash register system starting January 1, 2028, according to the current government draft.
Example 2: High total sales, very little cash
A business generates more than 100,000 euros in total revenue but receives less than 12,000 euros in cash per year. Under the current government draft, the proposed exemption would apply, and the business would not be subject to the new cash register requirement solely on the basis of its total revenue.
As a provider of modern point-of-sale systems, LocaFox is constantly addressing the legal requirements related to cash register management, TSE, fiscalization, and tax data recording.
Our point-of-sale systems already meet the technical requirements that apply to electronic point-of-sale systems. At the same time, we are closely monitoring the ongoing legislative process surrounding the planned mandatory use of electronic point-of-sale systems and will adapt our solutions to meet any new legal requirements.
We are here to advise retailers who are still using an open cash register today or who are unsure whether their existing point-of-sale system will meet future requirements.
Would you like to prepare your point-of-sale system for the new requirements in a timely manner? Contact us—together, we’ll determine which solution is right for your business.
*Reviewed and updated on November 9, 2026. This article is based on the German federal government’s draft bill in Bundestag Document 21/8867, the first reading in the German Bundestag on November 6, 2026, and the latest publications from the Federal Ministry of Finance. The legislative process has not yet been completed. Regulations, thresholds, deadlines, and exceptions may still change before the bill is finally enacted.
