Thank you for participating in our webinar on the reporting obligation in Germany! Here you will find an overview of the most important questions and answers that were asked during the event. Our goal is to give you a clear insight into the upcoming requirements and practical solutions.
The option of a cross-establishment mass notification was announced for 2026. At the end of May, initial documentation was published by MeinElster, which efsta has not yet checked for the technical feasibility of this service. As soon as the validation of the documentation has been completed and the feasibility of implementing this service has been checked, we will send information to our partners.
Yes, in the efsta portal: “Fiscal reports” > “Select company” > “Select location” > “Edit external POS systems”. All recorded information is stored here for any change notifications.
We can only answer this after reviewing the documentation published at the end of May.
Our recommendation is to report all POS systems that are in your possession (fixed assets) and consist of a combination of hardware and software as a replacement/test POS system without TSE according to § 146 AO. Please note that this is a recommendation and we are not allowed to provide binding legal information.
Yes, in the efsta portal: “Fiscal reports” > “Select company” > “Select location” > “Edit external POS systems”. All recorded information is stored here for any change notifications.
Please contact your Partner Manager for this.
For offline customers, it is technically impossible to transmit the required data using EFR and the efsta portal. If you would like to use our reporting service, a switch to an online EFR is required. In addition, data archiving is a basic requirement.
In the efsta portal, the company and business location data can be stored. This data is then automatically sent to the EFR service. When reinstalling the EFR, it is assumed that it is a new POS system. Therefore, the eAS data must be entered again.
The possibility of a mass report across multiple business locations was announced for 2026. At the end of May, initial documentation was published by MeinElster, which efsta has not yet checked for technical feasibility of this service. As soon as the validation of the documentation is completed and the feasibility of implementing this service has been checked, we will send corresponding information to our partners. A commitment to offer and make this function available by the end of July 2025 is not feasible.
The reporting obligation stipulates that an initial report must be submitted before June 30, 2025. We recommend that you implement the initial report before August 1st and, when the tax number changes, complete the initial report by deregistering and submitting a new report for the POS system with the new tax number. Please note that we are not allowed to provide binding legal information - this is only a recommendation.
In the efsta Portal: Fiscal reports / Select company / Select location / Edit external POS systems. All recorded information is stored here for any change reports. Please also use the end-user instructions: https://docs.efsta.eu/efr/DE/reporting#enduser-instructions
Please use the BMF's help guide to read the specification of the data fields: https://www.bundesfinanzministerium.de/Content/DE/Downloads/Steuern/FAQ-Ausfuellanleitung.html The corresponding information can be implemented for the efsta reporting service either by means of data transfer in EFR or by entering it in the efsta portal: https://docs.efsta.eu/efr/DE/reporting#terminal-data
We have recorded all mandatory fields required by law - we have not taken optional fields such as the software version used into account in our reporting service - as they are not mandatory.
In Germany, monthly sales reporting to the tax authorities is not required. The efsta reporting service solutions are aimed at all end customers, as the taxable end customer must report the POS systems used and all changes in due time - this service is therefore relevant for all taxable end customers, regardless of the number of POS systems used.
In Germany, monthly sales reporting to the tax authorities is not required. The reporting obligation requires that new POS systems and any changes relevant to reporting must be reported in every business location - this is checked every Monday in the efsta reporting service and corresponding information is made available to the participating taxable end customer.
Every new POS system that is used in a business location as well as any change must be reported within one month.
As discussed in the webinar, please contact your efsta partner manager. We will send you a side letter for signature and activate the automatic reporting service as soon as it has been signed. The service can then be ordered in the efsta portal under 'Fiscal reports/Company/Order automated report' (see presentation, slide 16). Fiscal reports > Company > Order automated report (see presentation, slide 16).
No, in Germany there is currently no legal requirement for a monthly sales report.
Based on your question, we assume that you are a taxable end customer. Please contact your POS system manufacturer so that they can activate the automatic reporting service for you - self-activation is not possible. Regarding your second question: Our reporting service provides the data for transfer to the MeinElster portal in the legally required XML format.
You can refer to the corresponding regulation at: https://www.bundesfinanzministerium.de/Content/DE/Downloads/BMF_Schreiben/Weitere_Steuerthemen/Abgabenordnung/2024-06-28-mitteilungsverpflichtung-nach-AO.html. Basically, electronic recording systems and the TSE connected to the system must be reported.
We recommend always using the purchase date of the currently used PC. Please also use the completion aid of the BMF: https://www.bundesfinanzministerium.de/Content/DE/Downloads/Steuern/FAQ-Ausfuellanleitung.html. Please note that we are not allowed to provide binding legal information - this is a recommendation.
The transfer of the TSE serial number has been implemented - if a TSE is connected to the EFR, the serial number is transferred to the creation of the mandatory XML file.
We have successfully completed ISO 27001 certification - the certificate will be available in April 2025 and published accordingly.
This is included free of charge in the manual reporting service and is already available in the efsta portal. In the automatic, paid reporting, it is a component of the service fee.
Here is our recommendation: If the replacement POS is connected to an EFR, you will automatically receive an email on Mondays stating that a new POS is in use at a business location. It must be defined whether the POS to be replaced is replaced and is no longer in your possession: Then the defective POS must be reported with a decommissioning notification. If the temporarily defective POS is repaired and used again, it has not been decommissioned - but the replacement POS must then be deregistered.
I assume you mean that MSPOS has been stored as the Elster contact in the efsta portal - then you will receive all change notifications from all your taxpayer customers. If this is not desired, you must adjust this in the efsta portal.
In principle, there are 3 different pieces of information to maintain:
Information on the taxpayer. This only needs to be maintained once per company. You can maintain this directly at the company in the properties under the "Elster Report" tab or on an organisation via CSV import. Please note that the "German tax number" with 13 digits must be entered for the tax number and not the VAT ID with DE...
Location data: Name and address of the location
POS data (serial number, software, manufacturer, model). Here you can download a CSV export for control purposes in the "Portal Export" menu with the type "Elster Data Control".
This question can only be answered once the documentation for mass notification has been published by Elster - was announced for May 2025.
Elster is expected to publish documentation in May 2025. We have to check this and adapt our reporting solution accordingly.
The BMF has described this in the FAQs: https://www.bundesfinanzministerium.de/#collapse170442-3-4 : 5. Do electronic recording systems that are not currently in use, but are kept for emergencies or in warehouses, for example, also have to be reported in accordance with Section 146a (4) AO?
If the taxpayer purchases electronic recording systems to record business transactions or other processes subject to recording requirements, these electronic recording systems are also subject to notification at the time of purchase, even if they are not intended to be used until a later date. If these electronic recording systems are not yet assigned a certified technical security device, it is sufficient to report only the electronic recording system.
If the electronic recording systems are held by other persons who do not use them to keep their own records (e.g. POS dealers or legally independent group companies), these electronic recording systems are not subject to notification.
The feedback from the efsta portal relates to missing data for a complete Elster notification. The master data quality - i.e. whether the address has been entered correctly, for example - is not checked.
Currently, no.
The download link does not change. The data can still be downloaded afterwards. All notifications can be viewed in the portal under "Fiscal notifications".
POS systems without TSE can be reported in compliance with the law via the efsta reporting service. The reference to complete data refers to MUST fields of the reporting obligation, such as the mandatory entry of the tax number.
Yes, please contact your efsta partner manager.
Only "open TSE notifications" are sent by email. As soon as the notifications have been created (downloaded), they will no longer be included in the email.
Here is the definition of the BMF in its FAQs: 5. Do electronic recording systems that are not currently in use, but are kept for emergencies or in warehouses, for example, also have to be reported in accordance with § 146a paragraph 4 AO?
If the taxpayer purchases electronic recording systems to record business transactions or other processes subject to recording requirements, these electronic recording systems are also subject to notification at the time of purchase, even if they are not intended to be used until a later date. If these electronic recording systems are not yet assigned a certified technical security device, it is sufficient to report only the electronic recording system.
If the electronic recording systems are held by other persons who do not use them to keep their own records (e.g. POS dealers or legally independent group companies), these electronic recording systems are not subject to notification.
Reference is also made to §854 BGB: German Civil Code (BGB)
§ 854 Acquisition of possession
(1) Possession of a thing is acquired by obtaining actual control over the thing.
(2) Agreement between the previous owner and the acquirer shall suffice for acquisition if the acquirer is in a position to exercise control over the thing.
Here is the definition of the BMF in its FAQs: 5. Do electronic recording systems that are not currently in use, but are kept for emergencies or in warehouses, for example, also have to be reported in accordance with § 146a paragraph 4 AO?
If the taxpayer purchases electronic recording systems to record business transactions or other processes subject to recording requirements, these electronic recording systems are also subject to notification at the time of purchase, even if they are not intended to be used until a later date. If these electronic recording systems are not yet assigned a certified technical security device, it is sufficient to report only the electronic recording system.
If the electronic recording systems are held by other persons who do not use them to keep their own records (e.g. POS dealers or legally independent group companies), these electronic recording systems are not subject to notification.
Reference is also made to §854 BGB: German Civil Code (BGB)
§ 854 Acquisition of possession
(1) Possession of a thing is acquired by obtaining actual control over the thing.
(2) Agreement between the previous owner and the acquirer shall suffice for acquisition if the acquirer is in a position to exercise control over the thing.
Here is the definition of the BMF in its FAQs: 5. Do electronic recording systems that are not currently in use, but are kept for emergencies or in warehouses, for example, also have to be reported in accordance with § 146a paragraph 4 AO?
If the taxpayer purchases electronic recording systems to record business transactions or other processes subject to recording requirements, these electronic recording systems are also subject to notification at the time of purchase, even if they are not intended to be used until a later date. If these electronic recording systems are not yet assigned a certified technical security device, it is sufficient to report only the electronic recording system.
If the electronic recording systems are held by other persons who do not use them to keep their own records (e.g. POS dealers or legally independent group companies), these electronic recording systems are not subject to notification.
Reference is also made to §854 BGB: German Civil Code (BGB)
§ 854 Acquisition of possession
(1) Possession of a thing is acquired by obtaining actual control over the thing.
(2) Agreement between the previous owner and the acquirer shall suffice for acquisition if the acquirer is in a position to exercise control over the thing.
In the efsta portal, an email address must be stored for each business location in order to make use of the weekly efsta mail service.
In the BMF's help text, the POS serial number is explained as follows: It is the serial number in accordance with § 6 number 6 KassenSichV for POS systems. For taximeters and odometers, you can usually find this on the device, often in the invoice or on the receipt. The serial number to be entered here corresponds to the serial number of the DSFinVK/DSFinV-TW. Reference is made to Tz. 1.16.2.5 and 2.2.3.1 of the AEAO on § 146a AO and chapter 9.3.1 of the Technical Guideline BSI TR-03153-1.
In the event of a cash audit, a verifiable scenario should be recorded in MeinELSTER.
Recording a SW Client serial number seems advisable here.
A data transfer such as the TSE serial number is not possible due to the lack of data transfer to the efsta portal.
Correct.
In the BMF's help text, the POS serial number is explained as follows: It is the serial number in accordance with § 6 number 6 KassenSichV for POS systems. For taximeters and odometers, you can usually find this on the device, often in the invoice or on the receipt. The serial number to be entered here corresponds to the serial number of the DSFinVK/DSFinV-TW. Reference is made to Tz. 1.16.2.5 and 2.2.3.1 of the AEAO on § 146a AO and chapter 9.3.1 of the Technical Guideline BSI TR-03153-1.
In the event of a cash audit, a verifiable scenario should be recorded in MeinELSTER.
In the BMF's help text, the POS serial number is explained as follows: It is the serial number in accordance with § 6 number 6 KassenSichV for POS systems. For taximeters and odometers, you can usually find this on the device, often in the invoice or on the receipt. The serial number to be entered here corresponds to the serial number of the DSFinVK/DSFinV-TW. Reference is made to Tz. 1.16.2.5 and 2.2.3.1 of the AEAO on § 146a AO and chapter 9.3.1 of the Technical Guideline BSI TR-03153-1.
In the event of a cash audit, a verifiable scenario should be recorded in MeinELSTER.
In the BMF's help text, the POS serial number is explained as follows: It is the serial number in accordance with § 6 number 6 KassenSichV for POS systems. For taximeters and odometers, you can usually find this on the device, often in the invoice or on the receipt. The serial number to be entered here corresponds to the serial number of the DSFinVK/DSFinV-TW. Reference is made to Tz. 1.16.2.5 and 2.2.3.1 of the AEAO on § 146a AO and chapter 9.3.1 of the Technical Guideline BSI TR-03153-1.
In the event of a cash audit, a verifiable scenario should be recorded in MeinELSTER.
The simulator TSE is filtered out from 14.04.2025 and now shows all TSE fields as empty, so cash registers with simulator TSE can be reported as if they had no TSE.
No.
The reporting obligation requires a report related to the place of business.
The obligation to report POS systems applies to permanent establishments in Germany.
Yes, you will receive the recording with our summary by e-mail.
An implementation of the efsta EFR with a data exchange with the efsta portal is the technical basis for using our reporting service. If you would like to report further POS systems used by a permanent establishment to POS reports already recorded in this way, you can add them manually to an existing report.
No.
The EFR must be deactivated. The message reports the historically recorded cash balance using the required gross method.
Yes, the fiscalization law states: If you use an electronic recording system, it must comply with the Cash Security Ordinance and the cash registers must be connected to a TSE.
The transitional period for the reporting obligation of cash registers in Germany stipulates that the status of the cash register systems, including the TSEs, must be recorded at the time of reporting. Any changes prior to this time do not need to be reported.
The transitional period for the reporting obligation of cash registers in Germany stipulates that the status of the cash register systems, including the TSEs, must be recorded at the time of reporting. Any changes prior to this time do not need to be reported.
POS system dealers do not have to register POS systems intended for sale to taxable persons in MeinElster. If a taxable person has POS systems in stock that are not yet in productive use, these must be reported - the possession of a POS system must already be reported.
Yes - the auditors justify this on the one hand by the fact that the POS system is owned by the taxable person and, on the other hand, a test receipt could be presented to the auditor, who will then also check it: is the test POS system registered yes/no.
By default, the email address in the Elster contact is empty. Emails are only sent to the taxable person once an email address has been entered as the Elster contact.
Please note that when using an efsta Offline EFR version, the legally required data is NOT transmitted to the efsta portal and is therefore not available for data export to fulfill the reporting obligation.
Emails will be sent to the Elster contact from the time an email address has been stored there, i.e. also to those taxable persons where not all the required information is available yet.
You can download an XML file per location at any time via an export function in the efsta portal for the purpose of transmission to MeinElster - regardless of the weekly emails.
What is meant here? The customer can download the XML via the portal (logged in or with a link via email). The portal API can also be used. However, this is only possible for partners (not end customers).
According to current knowledge, one XML file is planned per branch / business location - we are not aware of a summary of X business locations in one file.
efsta will implement this for customers with 5+ locations.
The possibilities of data transmission to the BMF are their responsibility - we have no information about a planned change to the MeinElster portal for the purpose of cash register registration. Please contact the BMF or BSI with this question.
Is there an example of this? As we understand it, the tax number only exists per company.
Since, in our estimation, this allows for a corresponding scope of interpretation in the BMF's rules, we recommend that you consult a tax advisor.
Yes - mainly intended for systems that are test systems or are kept in stock as a reserve, for example.
Not planned.
Each XML file per place of business is prepared using a so-called gross method: any POS/TSE etc. that has ever been registered/deregistered at this place of business is included in the XML file. In the event of an audit, the auditor can always access the entire history.
No
Since Offline EFR does not communicate with the efsta portal, a data export from the portal cannot currently be implemented. If possible, please switch to an Online EFR. Exporting the serial number of the TSE is not currently on our development roadmap.
We cannot give any binding legal advice here, as there is a certain amount of room for interpretation, as mentioned in the webinar. Please ask a tax advisor how to implement this.
The regulations require several data fields such as the software of the cash register or the serial number of the system used. Please read the complete BMF help.
If you submit all requested data via our efsta EFR API – yes – but you must add a contact email address for a responsible person of your taxable customer. It is also possible to add the data of the taxable person via the portal API (available via docs.efsta.net).
Deadlines:
From 01.01.2025, all electronic POS and cash register systems used in companies must be reported to the responsible tax office. Existing cash registers must be reported to the tax office by 31.07.2025 at the latest (late registration deadline).
For new systems (purchased from 1 July 2025): Registration within one month of purchase. For decommissioning: From 1 July 2025, a notification must also be made if a recording system is decommissioned; prior to this, the notification of the acquisition may have to be made retroactively.
We are considering offering this service in the future; the decision will be made at the end of the first quarter of 2025.
Not yet planned.
All changes that are made in one of your branches and must be reported via MeinElster for the reporting obligations of cash registers must be made within 30 days.
Additional POS systems not registered with efsta can be manually added in MeinElster - see the BMF's help file.
A notification is required if there is a new serial number, software, hardware, or TSE.
The TSE serial number is automatically detected by the EFR and sent to the efsta Cloud. The customer must enter the POS serial number themselves in the portal under FiscalRegister when clicking on the cloud, or alternatively enter it in the EFR.
The reporting obligation requires that electronic recording systems in Germany be registered by the taxable company. Since the test system in your example is not operated in Germany and a tester may find a test receipt, this test system does not need to be reported in our understanding.
An XML file is always required per location/business premises. It is not possible to report several locations with one file.
After an initial recording of the data subject to reporting, all changes subject to reporting, such as the replacement of POS systems (registration/deregistration), a change of the TSE, etc., must be recorded in Mein Elster within one month in accordance with §146a.
This is subject to your assessment or decision as to how much data maintenance you, as a POS manufacturer, can and want to take on - as well as whether you would like to offer this as a (chargeable?) service for your customers.
If there are relevant changes, an automated e-mail will be sent to the stored ELSTER contact with a link that can be used to request and download the XML. A login by the entrepreneur is not necessary for this.
Example XML available from 01.12.2024
Has been defined in the interface since the introduction of the German Cash Security Ordinance. In the DSFinV-K, however, this data is optional with the exception of the serial number.
Recording, questions and deck will be made available in a collected form.
Only German companies are recorded.
Each POS system receives its own serial number, which is usually located on the device itself. Ideally, this number should be printed on the POS device so that an auditor can check it.
The XML file can be customized by the business owner in the efsta portal before it is created and downloaded.
We interpret the notification requirement to mean that updates are not subject to notification, but major software updates or software extensions are. For a legally binding assessment, please contact a tax advisor.
If you enter data EXCLUSIVELY MANUALLY in MeinElster - i.e. data such as the POS serial number, POS type, etc. - this data will not be transferred to the efsta portal and will therefore not be available as an automated XML file download for, e.g., change notifications. If this entry of data subject to notification in the efsta portal is not important to you and you are aware that data not entered will not be available in the XML notification file, the entry of the terminal data can be seen as optional.
The KOMet-AG stands for: Working Group Consensus Communication Procedure Electronic Recording Systems. There is a weekly online meeting where questions about the notification obligation are discussed. The KOMet-AG is NOT responsible for the legal basis of a KassensichV - this is the responsibility of the BMF.
The Komet-AG is explicitly not the nationwide information center for all questions regarding § 146a (4) AO!
The assistance offered only concerns eAs software developers.
The goal is a successful introduction of the Komet notification via the ERiC interface.
End customers cannot direct questions to the KOMet-AG.
POSDeactivationDate is naturally empty for active POS systems. If a POS system is not yet active, POSActivationDate is empty. For POS systems that are not yet active or have been deactivated, the TSE fields are also empty, as there is no TSE connected to the POS system. All other fields should be filled.
The specified email addresses will receive a link in case of relevant changes, under which the data can be checked and edited again, as well as an XML with the current data can be requested and downloaded.
1. Yes, the export exists to identify unregistered or incorrectly registered data before the notification is created.
2. The software version is not relevant for the notification and only exists as an optional field.
3. The manufacturer of the POS system should be listed under Manufacturer.
4. No, a new EFR version is not required for the TSE notification. All the necessary data has already been recorded in the EFR for the DSFinV-K and sent to the efsta Cloud since the beginning of the Cash Register Security Ordinance.
Each business location/site must be reported separately.
We interpret that computers that are not specifically set up for POS operations and do not use POS software to record business transactions are not subject to the reporting requirement - from the point in time when the computer uses a POS client, it must be reported. The computer owned by the taxpayer becomes a POS system upon client installation - even without a TSE. Please note that this is an interpretation by efsta and has no legal validity - for this purpose, we must refer you to a tax advisor.
The number of electronic recording systems must be reported within one month per business location when changes occur.
Special characters are taken into account in the export.
We interpret a sub-supplier as one who has POS systems in stock for the purpose of selling them to taxable end customers - this is to be regarded as current assets and is therefore not subject to reporting requirements. The taxable end customer who buys a POS system has this as fixed assets and must already report the possession of the POS system. Please note that this is an interpretation by efsta and has no legal validity - for this purpose, we must refer you to a tax advisor.
Correct.
We interpret POS input devices as follows: If input devices, such as tablets, smart phones or other operating devices, are directly integrated into the POS system and are used to enter POS transactions, they are regarded as part of the POS system. In this case, they are covered by the reporting requirement, as they contribute to the recording and storage of data. Please note that this is an interpretation by efsta and has no legal validity - for this purpose, we must refer you to a tax advisor.
Thank you for this important question. Currently, we create ONE XML reporting file per location / POS system in the portal export logic. We will check this point in our development to see how we can implement this if necessary.
Please contact our support team: Use our ticket system, which you can reach via ticket@efsta.eu.
The first report on POS systems must be submitted from 1 January 2025 with a six-month transition period until 30 June 2025 – with a one-month extension for reporting new POS systems, the report must be submitted by 31 July 2025 at the latest. After the first report, you only need to report changes (decommissioning of POS systems or TSE or new POS systems, etc.) and new branches.
Bei Neuinstallationen sowie bei bestehenden Installationen von Registrierkassen muss im efsta-Portal vermerkt und überprüft werden, ob der Wert >>interne Filial-ID („Int. FILIAL ID“)<< im Portal mit dem TL (Terminal Location) (siehe DE-Leitfaden 5.2.) im efsta EFR übereinstimmt.
Minor SW updates do not need to be recorded – the authorities would like to be informed about major SW release updates if significant functions or the architecture change.
This is not yet planned. The obligations of the data transmitter to verify the identity of the taxable company are complex and we will inform you if efsta offers this service.
As far as we know, the tax authority does not inform taxable customers for this reason.
The initial registration of POS systems must occur from January 1, 2025, with a 6-month transition period until June 30, 2025 – with an additional month to register new POS systems. The registration must be completed by July 31, 2025, at the latest.
Will be sent by email together with a summary.
Will be sent by email together with a summary.
As long as the taxable customer uses a valid TSE certified by the BSI, they are free to choose which TSE (USB, SD card, cloud) from which provider they want to use. If they change a TSE, this must be documented in the process documentation and is also relevant for the reporting obligation – the new TSE serial number must be reported.
The taxable customer has until the end of June (plus one month) to complete the registration of the POS systems.
The addition or merging of reporting data from different POS systems must be carried out manually by the taxpayer in the MeinElster portal.
For sales inquiries, please use our ticket system, which you can reach at sales@efsta.eu.