Cash register mandate planned for 2028: prepare shop and POS

The German government wants to introduce a cash register mandate: anyone with more than €100,000 in total annual turnover would have to record their till takings with an electronic cash register system in the future; businesses with cash turnover below €12,000 a year are exempt (BMF). At the same time, the paper slip is to be replaced by a digital receipt on January 1, 2028 (German Bundestag). The federal cabinet adopted the bill on September 23, 2026; the Bundestag and the Bundesrat have not decided yet. For online merchants with a store, a market stall or pickup with cash payment, the topic still belongs in the plan for 2027: the till would then have to provide a receipt that reaches the customer electronically, and shop and customer account can take it in. This post sets out what the draft provides, where it is still open and how till and online shop can prepare through integrations.

What the government bill provides

The federal cabinet adopted the draft act on the further development of cash register records, on combating tax evasion and on the further digitization of commercial and tax records on September 23, 2026 (BMF). The Federal Ministry of Finance (BMF) calls it the Second Cash Register Act for short (BMF). The starting point is the so-called open till: a cash box without electronic recording, in which takings are not recorded at all or only by hand. According to the ministry, there are still about 115,000 of them (BMF). The ministry considers their turnover prone to abuse (BMF).

The core of the bill is a new section 146b of the German Fiscal Code. Under it, taxpayers running an agricultural, forestry or commercial business or working freelance must use an electronic recording system if their total turnover exceeds €100,000 in a calendar year (government bill). This means a system that meets today's requirements of section 146a of the Fiscal Code: it is protected by a certified technical security device, TSE for short, and produces records according to the tax authority's digital interface for cash register systems, the DSFinV-K (government bill). Taxpayers who accept cash payments and whose cash turnover is below €12,000 in the calendar year are not covered (government bill). The bill does not prescribe a specific type: a cash register, a complex POS system or a cloud POS are equally possible (government bill).

Two thresholds: total turnover and cash

The first threshold refers to total turnover within the meaning of section 19 paragraph 2 sentence 1 of the German VAT Act (government bill). That is the sum of the entrepreneur's taxable turnover calculated on the basis of payments received, minus certain tax-exempt turnover (German VAT Act). The definition looks at the entrepreneur, not at the till. For a merchant selling online and in a store, the online turnover therefore also counts toward the €100,000 limit. Anyone running a store alongside an online shop can thus be above the first threshold even if only a small part of the turnover is generated at the counter. How online retail and the physical store fit together overall is covered in the post on omnichannel strategy.

That is why the second threshold is often decisive: cash turnover below €12,000 in the calendar year (government bill). The explanatory memorandum stresses that this exemption only applies if a taxpayer also accepts cash (government bill). Summaries word the limit differently: even the ministry's topic page states it once as "below 12,000 euros" and once as "up to 12,000 euros" (BMF). What counts is the wording of the act, and in the draft that wording is "below". It is also worth separating what is recorded from what is counted: according to the explanatory memorandum, cash payments and also debit or credit card payments must be recorded in the electronic recording system (government bill), but only turnover in cash counts for the exemption.

• Online shop with a store. Shop and store together take more than €100,000, and the store accepts notes and coins. If cash turnover reaches €12,000 or more, the business would be subject to the mandate under the draft (government bill).
• Pickup with cash payment. Anyone handing over shop orders at the warehouse or store against cash generates cash turnover there. Under the wording, it counts toward the second threshold even though the order started online.
• Market stall and trade fair. Sales at changing locations are part of total turnover. For temporary and mobile points of sale, the discussion draft of an exemption ordinance provides an exemption with daily subsequent recording (BMF discussion draft).
• Selling only via marketplaces. Anyone selling exclusively through an electronic marketplace or platform is to be exempt under the discussion draft; the turnover still counts toward the turnover limit (BMF discussion draft).
• Own online shop without cash. According to the explanatory memorandum, the cash exemption is tied to accepting cash (government bill). Neither the bill nor the discussion draft names a separate exemption for a merchant's own online shop. How the mandate will be interpreted here is open and belongs with your tax advisor before any investment.

When the mandate is to apply

For the start, the government bill provides a transitional rule: if the turnover limits are exceeded in 2026, the mandate applies from January 1, 2028 (government bill). Under the draft, the current calendar year is therefore already the counting year. Anyone exceeding the limits for the first time in 2027 or later falls under the regular rule: the mandate then applies from July 1 of the year following the year in which the limit was exceeded (government bill). It ends at the close of the second consecutive calendar year in which the conditions are no longer met (government bill).

Between the ministry draft and the cabinet decision, the counting year has thus been brought forward by one year: from 2027 (ministry draft) to 2026 (government bill). The text may still change in the parliamentary procedure as well. For planning, this means: secure the 2026 figures now because they decide under the current draft, but align investments in devices and integrations with the adopted version. The wider context of deadlines is shown in our 2027 deadline calendar for online shops.

The digital receipt replaces the paper slip

Today, the duty to issue receipts applies: anyone recording transactions with an electronic recording system must issue a receipt to the other party in close temporal connection and make it available (German Fiscal Code). The receipt can be issued on paper or, with the recipient's consent, electronically in a standardized data format (Cash Register Anti-Tampering Ordinance). The mandatory details must be readable without a machine, readable from a QR code or contained in an electronic invoice (Cash Register Anti-Tampering Ordinance). In practice, the paper slip is therefore the rule and the electronic receipt the exception with consent.

The government bill reverses this. The new section 146a paragraph 2 of the Fiscal Code requires providing the other party with an electronic receipt about the transaction in a standardized data format; the act calls this the duty to provide receipts (government bill). It is to apply from January 1, 2028 (government bill), and to everyone recording with an electronic till, not only to businesses that will fall under the cash register mandate. Customers are under no obligation to accept the electronic receipt (BMF). The right to a paper acknowledgment of receipt under section 368 of the German Civil Code remains; however, the merchant only has to issue a paper receipt at the customer's request (government bill). In the Cash Register Anti-Tampering Ordinance, the sentence on paper form and consent is deleted, while the mandatory details of a receipt remain (government bill).

Technically, the route is open: the explanatory memorandum stresses technology neutrality and sets no requirements for how the receipt is provided or transmitted (government bill). According to the memorandum, many POS systems, especially cloud tills, can already issue receipts by email, as a QR code or printed on request (government bill). What remains open is how the standardized data format will look in detail; the act names it but does not describe it. For planning, this means: output should run through a component that can take on a new format without having to rebuild till and shop at the same time.

Shop and store till: who keeps which receipt

The obligations attach to the till. Electronic recording systems within the meaning of the Fiscal Code are electronic or computer-based cash register systems and cash registers; electronic accounting programs are expressly excluded (Cash Register Anti-Tampering Ordinance). An online shop that handles orders with an invoice does not appear in that list. It does, however, become the obvious place where customers find their receipts again: next to the invoice from the online purchase, also the POS receipt from the store. The roles stay the same as today: the till creates and signs the tax receipt, the shop displays it. How till, ERP and shop share stock and the receipt chain is described in the post on connecting a POS system to the online shop. The online shop's invoice follows its own rules, summarized in the post on e-invoicing requirements for online shops.

1. Identify the customer if they wish. A loyalty card, app code or customer number links the till transaction to the account in the shop. Without identification, the QR code remains.
2. Complete and sign the transaction. The till completes the transaction, the TSE assigns the transaction number, signature counter and check value.
3. Create the receipt. The till creates the receipt in the prescribed data format with the mandatory details of the Cash Register Anti-Tampering Ordinance.
4. Provide it. For every customer as a QR code on the display, for identified customers also as an entry in the customer account.
5. File it in the shop. The shop stores a reference to the receipt and displays it in the account without changing its content.
6. Find it again for returns. Exchange and refund refer to the receipt ID, regardless of whether the purchase took place in the store or online.

{
  "receipt_id": "K1-2028-000417",
  "source": "pos-store-1",
  "tse_serial": "example-tse-01",
  "transaction_number": 417,
  "signature_counter": 1032,
  "format": "standardized-receipt",
  "provided_via": ["qr-code", "customer-account"],
  "customer_account_id": "c-58213",
  "retrieval_url": "https://shop.example/account/receipts/K1-2028-000417",
  "related_order_id": null
}

The example shows the split: content and signature belong to the till, the shop only holds the reference and the retrieval path. That way the receipt stays unchanged even if the shop rebuilds its layout or account. Because the customer does not have to accept the receipt (BMF), the customer account should remain an offer and not become a precondition for the purchase. Anyone who wants to merge customer accounts from an existing system for this will find the groundwork in the post on onboarding existing customers from the ERP.

Pickup, market stall and marketplace

Click and collect connects both worlds. If payment is made online, no cash turnover arises at the pickup point. If cash is paid only at pickup, it arises there, and the transaction belongs in the till together with its receipt. For merchants close to the cash limit, the choice of payment methods at pickup can therefore help decide whether the mandate applies. How reservation, pickup deadline and till integration work together is shown in the post on store pickup as a process.

For further exemptions, the ministry is to be able to issue an ordinance with the consent of the Bundesrat (government bill). The BMF has published a first discussion draft of this exemption ordinance for better understanding; the actual ordinance procedure is only to start after the act has been promulgated (BMF). The discussion draft as of July 22, 2026 contains, among other things, these points (BMF discussion draft):

• Anyone selling exclusively via an electronic interface within the meaning of section 25e paragraph 5 of the German VAT Act or via a platform is exempt, including for a separately managed part of the business. The VAT Act defines such an interface as an electronic marketplace, platform, portal or similar (German VAT Act). How marketplaces are connected to shop and ERP is shown on our page on marketplace integrations.
• An exemption is planned for payments at temporary or mobile points of sale, for example at markets; the takings must, however, be recorded in an electronic recording system daily afterward.
• Honesty boxes without sales staff are not to fall under the mandate; their takings are recorded afterward on a regular basis and their use documented.
• Exempt turnover still counts toward the €100,000 turnover limit (BMF discussion draft).

Effort according to the government's calculation

The government bill also quantifies the consequences. The government expects 114,800 tills that will have to be newly purchased because of the mandate; around 27% of today's POS stations are cloud-based (government bill). For the TSE it assumes annual fees of €93 per TSE, with two to three tills able to run on one TSE (government bill). Overall, the annual compliance cost for businesses is nevertheless to fall, by €106,192,000, mainly due to the switch from paper to digital receipts (government bill).

Roadmap from 2026 to 2028

Preparation has one advantage: the figures for checking the thresholds are usually already available. According to the explanatory memorandum, taxpayers already have to determine and record their takings at least daily, separated into cash and non-cash, regardless of the type of till (government bill). Anyone transferring this data cleanly into accounting, for example via a DATEV integration, can evaluate both thresholds without much extra effort.

1. By the end of 2026: secure the figures. Evaluate total turnover and cash turnover for 2026 separately, including pickup, markets and vouchers. Under the draft, 2026 is the counting year for the start on January 1, 2028 (government bill).
2. Early 2027: check the till. Does the existing till have a TSE, a customer display and an interface for electronic receipts? Anyone running an open till plans the purchase.
3. First half of 2027: define the data model. Define customer number, receipt ID and retrieval path between till, ERP and shop.
4. After promulgation: build and test. Implement receipt output via QR code and customer account, test returns across channels, prepare notifications to the tax office.
5. From January 1, 2028: operation. Digital receipts as the rule, paper only on request, exemptions according to the ordinance then in force.

How we support till, shop and receipts

Our focus is connecting the systems. We plan and build interfaces between till, ERP and Shopware shops, reconcile stock between store and online shop and set up the receipt route so that a POS receipt arrives in the customer account without being altered there. How we reconcile stock across channels is described in the post on real-time inventory sync.

Under the draft, the cash register mandate and the digital receipt are two separate obligations with the same start date. Anyone using 2027 to bring till, shop and customer account onto a shared receipt route is prepared for both, regardless of how the thresholds look in the final version.