Germany is currently one of the few European countries where businesses are still permitted to use open cash registers under certain conditions. However, a recent draft bill from the Federal Ministry of Finance could change that starting in 2027. The goal of the proposed regulation is to more effectively combat tax evasion by mandating the use of electronic recording systems.
This development is particularly relevant for software providers. If the draft is implemented in its current form, demand for legally compliant POS, ERP, and cash register systems will increase significantly. At the same time, providers and integrators may face new requirements.
Currently, there is no general requirement to use a cash register in Germany. In principle, businesses can choose between an electronic cash register system and an open cash register, provided they comply with the legal requirements for proper cash management.
However, anyone who already uses an electronic point-of-sale system must comply with the requirements of the Point-of-Sale Security Regulation (KassenSichV). This includes, in particular, the use of a certified technical security device (TSE) designed to prevent tampering with point-of-sale records. The draft bill explicitly builds on these existing regulations.
Unlike in countries such as Austria, there is currently no general requirement to use a cash register in Germany. That could change starting in 2027.
According to the current draft bill, a legal requirement to use cash registers is to be introduced effective January 1, 2027. Businesses with annual sales exceeding 100,000 euros will be required to use an electronic recording system in the future. Open cash registers would, in principle, no longer be permitted for these businesses.
The draft sets out several objectives:
In addition, the draft bill aims to expand the investigative powers of the tax authorities and create additional options for sanctions. At the same time, the draft bill provides for adjustments to the requirement to issue receipts.
Since this is a draft bill, many issues remain unresolved.
The German Association of Tax Advisors points out, among other things, that it has not yet been clearly defined whether the revenue threshold of 100,000 euros refers to total revenue or exclusively to cash revenue. In addition, possible exceptions and transitional provisions are still undecided at this time.
Possible special provisions for the following have also not yet been definitively clarified:
Companies should therefore closely monitor future legislation.
The proposed regulation could have significant implications for providers of POS, ERP, and point-of-sale software.
Many companies still use open cash registers. The draft bill explicitly states that the mandatory use of cash registers is intended to replace these systems with electronic recording solutions.
If the regulation is implemented, affected companies will need appropriate software and hardware solutions. Providers that already offer legally compliant point-of-sale solutions for the German market could benefit from this in particular.
Since the draft builds on the existing requirements of Section 146a of the German Fiscal Code (AO), the certified technical security device remains a central component of cash register systems that comply with the law. The mandatory use of electronic recording systems would further increase the importance of TSE integrations.
For software providers, this means:
are increasingly becoming standard requirements.
ERP systems could also be affected by this development. If more companies begin using electronic point-of-sale systems, the importance of standardized interfaces between POS, ERP, and accounting will typically increase.
For ERP providers, this may mean additional integration requirements, particularly in the following areas:
If the requirement to use cash registers is indeed introduced in 2027, many companies will have to adapt their existing processes. This creates a potential need for:
System integrators and providers of fiscalization solutions, in particular, could benefit from this.
Even though the final details of the regulation have not yet been determined, it is advisable to keep an eye on future legislation starting now.
In particular, providers of POS and ERP systems should check:
The planned mandatory use of cash registers in Germany is one of the most significant potential changes in the field of cash register management since the introduction of the TSE requirement. While many details remain to be determined, it is already becoming clear that POS, ERP, and cash register software providers could be among the market participants most indirectly affected. Should the draft bill be implemented, demand for legally compliant electronic recording systems is likely to increase significantly. This therefore presents an opportunity for software providers to prepare for the potential requirements early on and to support customers during the transition.
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