Electronic reporting obligation for cash register systems

In accordance with Section 146a (4) AO, cash register systems must be reported electronically to the responsible tax office from January 1, 2025. The reporting obligation for electronic cash register systems in Germany is part of the measures to combat manipulation and tax evasion in the cash register sector.

Key points on the reporting obligation for POS systems in Germany

1. reporting to the tax office: Companies that use electronic cash register systems or cash registers with a technical security device (TSE) are obliged to report these systems per business premises to their responsible tax office.

2. electronic transmission: The declaration must be made electronically via the My ELSTER portal.

3. information on the cash register: certain information must be provided with the report, including:
○ type of cash register system
○ serial number of the cash register
○ certificate of the technical security device (TSE)
○ date of acquisition/commissioning

4. deadlines: The taxable person must submit the required data from 01.01.2025 with a deadline of 30.06.2025 at the latest.

5. obligation to use the TSE: All cash register systems must be equipped with a TSE that ensures that all cash register transactions are recorded in a tamper-proof manner and can be made available for audits.
6. electronic recording systems that are acquired from July 1, 2025 must be reported within one month (Section 146a (4) sentence 2 AO). This also applies to systems that are decommissioned after this date. Important: When reporting the decommissioning of electronic recording systems, the acquisition must be reported beforehand.

According to the current status of the authorities (BMF), automated reporting is only possible in accordance with Section 87d of the German Fiscal Code (AO). This regulation concerns data transfers to tax authorities on behalf of the taxpayer and corresponds to the function of a tax advisor or the taxpayer himself.

The efsta timeline for mandatory reporting at a glance

1.10.2024 ->

Data completion / check

Company data - contact details can be completed by the efsta partner or the taxable end customer using an export/import option. The aim of this data check is to have collected / validated all legally required data to fulfill the reporting obligation.

partners are informed if mandatory data is missing for the AO§146 form. This data must be entered in the efsta portal so that we can automatically create your XML file.

1.12.2024 ->

Creation of the initial Elster-AO§146 XML export

‍AutomatedXML creation for all companies based in Germany.

Automatic e-mail notification to all companies (by efsta) so that the XML export can be checked for validity.

1.1.2025 ->

First AO§146 XML uploads are now possible via MeinElster

‍‍Aftera check/validation of the XML file by the taxpayer, the files can be uploaded directly via their MeinElster account.

30.06.2025

Deadline for fulfilling the reporting obligation via MeinElster XML upload to 30.06.2025

‍Eachtaxable company must have uploaded its current XML file.

Reportable changes to locations, cash registers or TSEs are sent weekly by efsta by e-mail to all affected companies, together with a corresponding link to the new XML file, which must be uploaded to MeinELSTER within 30 days.

XML data for taxpayers

Compliance as a service with efsta - simple provision of reporting data for uploading to My ELSTER or the ERiC interface

The XML data is formatted in such a way that it can be uploaded via the "My ELSTER" program or the ERiC interface for the taxpayer! This is compliance as a service!

The XML file can be downloaded and viewed via the efsta portal API or via the efsta portal. For this purpose, the taxable person receives an e-mail with a link (without login) to the XML file, with an overview of the reportable information. The taxable company must check the data for accuracy using an efsta XML viewer. If changes to the company data or permanent establishments are necessary, these must be made in the efsta portal.

From 01.10.2024, an export and import function for company data and their email addresses will be available to facilitate the updating of email addresses by the end of the year.