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Mandatory cash register requirement from 2028: who is affected, which thresholds and exemptions apply, what the KassenSichV and TSE require, and how to prepare.
For many businesses, the open cash register with a cash box and handwritten cash book will soon be a thing of the past. On 23 September 2026, the German Federal Cabinet adopted the draft bill introducing a mandatory cash register requirement in Germany: businesses with total revenue of more than EUR 100,000 will have to use an electronic POS system with a certified technical security device (TSE) from 2028 (Bundesministerium der Finanzen: „Digitale Kassen und das Ende der Papierbons“, 2026.)
This article explains why the requirement is being introduced, who it affects, which exemptions are planned, and how retailers, hospitality businesses and service providers can prepare now.
The requirement is part of the action plan against tax and financial crime presented by the Federal Ministry of Finance and the Federal Ministry of Justice in July 2026. Federal Finance Minister Lars Klingbeil summed up the aim as follows: "Honest people must not end up being the fools (Bundesministerium der Finanzen und Bundesministerium der Justiz und für Verbraucherschutz: „Aktionsplan gegen Steuer- und Finanzkriminalität: Entdeckungsrisiko und Abschreckung spürbar erhöhen“, 2026.")
The focus is on cash-intensive sectors. According to the Federal Ministry of Finance, more than 100,000 open cash registers are still in use in Germany. Their revenue is considered vulnerable to abuse because it is either not recorded at all or only recorded by hand.¹ An electronic POS system with a TSE, by contrast, stores every transaction in a tamper-proof manner and makes the data available to the tax authorities in a standardised format. This increases the risk of detection and protects businesses that pay tax on their revenue correctly.
The new requirement builds on existing rules. The German Cash Register Security Ordinance (KassenSichV) has applied since 2020. However, it only applies to businesses that already use electronic POS systems. Businesses using an open cash register have not been covered so far. The mandatory cash register requirement is intended to close this gap.
Year | Regulation | What applies |
|---|---|---|
2020 | KassenSichV | Electronic POS systems require a certified TSE, and receipts must be issued. |
2025 | Reporting obligation | Electronic POS systems must be reported to the tax office via ELSTER. |
2028 | Mandatory cash register requirement (planned) | Businesses above the revenue thresholds must use an electronic POS system with a TSE. An electronic receipt is provided instead of a paper receipt. |
Recording is also subject to the GoBD, the German principles for the proper keeping of books and records in electronic form. Under these principles, POS data must be stored completely, unalterably and in a form that the tax authorities can analyse, for example via the standardised DSFinV-K interface.
People often still talk about a mandatory cash register requirement from 2027, as this was what the coalition agreement originally stated (CDU, CSU und SPD: „Verantwortung für Deutschland. Koalitionsvertrag für die 21. Legislaturperiode“, 2025.) Under the current draft bill, however, the requirement will start on 1 January 2028 for all businesses that already exceed the revenue thresholds in 2026. Businesses that generate more than EUR 100,000 in total revenue and more than EUR 12,000 in cash revenue for the first time in 2027 must use an electronic POS system with a TSE from 1 July 2028. The requirement only ceases to apply once the conditions have not been met for two consecutive calendar years.
The draft does not distinguish between sectors. Those mainly affected are businesses in which a lot of payments are still made in cash:
Special rules apply to clubs and associations when calculating revenue, for example with regard to membership fees and donations. The Tillhub by Unzer guide to the mandatory cash register requirement for clubs and associations explains the details. The guide Mandatory cash register requirement Germany 2028 provides a detailed overview of the legislative process and the criticism from business associations.
In parallel, the Federal Ministry of Finance is planning a requirement for card acceptance in the broader sense: businesses that take payments on site will have to offer at least one digital payment option in addition to cash, such as card or smartphone. This emerged from key points that became public in September 2026. No revenue threshold is planned, and the aim is for it to start in 2027 (tagesschau: „Geschäfte sollen künftig Kartenzahlung anbieten müssen“, 2026.)
Legally, this is a separate initiative, but its aim is related: alongside freedom of choice for customers, it is also about traceable revenue, as digital payments are documented automatically. No draft bill has yet been published. One detail is important for the mandatory cash register requirement: card payments do not count towards cash revenue, which determines whether the EUR 12,000 exemption applies.
The mandatory cash register requirement is set to start on 1 January 2028. What matters is when a business exceeds the revenue thresholds: if you are already above them in 2026, you must have switched over by the start of 2028. If you exceed them for the first time in 2027, you have until 1 July 2028. Businesses still working with an open cash register should check in good time whether they are affected and plan the switch calmly. If you are switching anyway, you can sort out your POS system and card payments in a single step.
Tillhub by Unzer offers POS solutions with TSE, DATEV export and integrated card payments from a single source.
Businesses that take less than EUR 12,000 in cash per year are exempt, even if their total revenue exceeds EUR 100,000. The Federal Ministry of Finance may set out further exemptions by statutory ordinance, for example for honesty boxes, direct marketing of agricultural produce, and weekly markets and fairs. Simplified rules are planned for temporary events.
Anyone who fails to use an electronic POS system with a TSE despite being required to do so will in future commit an administrative offence and risk a fine of up to EUR 25,000. Failing to issue a receipt will also become an administrative offence.¹ The draft bill creates a separate criminal offence for manipulation software: commercial distribution may be punished with up to five years' imprisonment, and its use with up to three years (Bundesregierung: „Entwurf eines Gesetzes zur Fortentwicklung von Kassenaufzeichnungen und zur Bekämpfung von Steuerhinterziehung sowie zur weiteren Digitalisierung handels- und steuerrechtlicher Aufzeichnungen“, Bundesrat-Drucksache 585/26, 2026.)
Cloud-based POS systems with a cloud TSE usually need less hardware than traditional cash registers and are generally billed monthly, so you don't need a large upfront investment. For a fixed shop or premises, an iPad POS system works well and can be expanded with a receipt printer, cash drawer and card terminal as needed. If you take payments on the move or in a small space, the mobile POS Go is a compact alternative: POS software, card terminal, barcode scanner and receipt printer all come in one device. Either way, your POS system and card payments come from a single source and only need to be set up once.
The best place to start is your revenue for 2026 and 2027. If your total revenue and cash revenue are likely to be above the thresholds, it makes sense to switch early. Choose a POS system with a certified TSE, report it to the tax office via ELSTER and create GoBD-compliant procedural documentation. Your tax adviser can help you with this.
A legally compliant POS system meets the KassenSichV requirements. It works with a certified TSE, stores all transactions unalterably in line with the GoBD, allows data export via the DSFinV-K and is registered with the tax office. From 2028, it must also be able to provide electronic receipts. Tillhub by Unzer POS systems meet the current requirements and are updated to keep pace with new regulations.
Note: This article is for information purposes only and does not constitute legal or tax advice. For binding information, please contact your tax adviser or your local tax office.