Federal Government Plans Electronic Receipts from 2028
The Bundesregierung (German Federal Government) intends to replace the existing obligation to issue paper receipts with an obligation to provide electronic receipts from 2028. The basis for this is the draft Act on the Further Development of Cash Register Records and the Fight Against Tax Evasion and on the Further Digitalisation of Records under Commercial and Tax Law (Bundestagsdrucksache 21/8867, German Bundestag printed paper 21/8867).
With the draft legislation, the Federal Government is pursuing three objectives in particular:
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Consumer protection and the digitalisation of records under commercial and tax law are to be promoted.
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Dispensing with paper receipts is intended to reduce the environmental impact.
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The manipulation of cash register records and tax evasion are to be made more difficult.
The draft therefore does not provide for the complete abolition of the obligation to provide receipts. Instead, the obligation to issue paper receipts is to be replaced by an obligation to provide receipts electronically.
Electronic Cash Register Systems for Businesses with Revenue of €100,000 or More
Obligation to Use an Electronic Cash Register
From 2028, businesses with total revenue of €100,000 or more are to be required to maintain an electronic cash register equipped with a technical security system that meets the statutory requirements. The systems used must satisfy the requirements of § 146a Abgabenordnung (German Fiscal Code).
The underlying transaction records are protected by the technical security system and generated in accordance with the Digitale Schnittstelle der Finanzverwaltung für Kassensysteme (DSFinV-K, Digital Interface of the Fiscal Administration for Cash Register Systems). According to the explanatory memorandum to the draft legislation, the immediate cryptographic protection and recording of the data is intended to reduce the scope for subsequent alterations.
Risks Associated with Open Cash Boxes
The Federal Government points out that open cash boxes without electronic recording systems continue to be used in practice. Particularly in sectors with a high proportion of cash payments, this creates an easier means of failing to declare revenue in full while also making such conduct more difficult to prove.
According to the explanatory memorandum to the bill, the use of open cash boxes therefore entails an increased risk that revenue will not be properly recorded and taxes will be evaded. By contrast, electronic cash register systems are intended to present less potential for manipulation because the recorded data is immediately secured using cryptographic methods.
Electronic Provision to Replace Paper Receipts
The draft legislation does not provide that businesses will no longer be required to provide any receipt at all. Only the form is to change: instead of being issued on paper, receipts are generally to be provided electronically.
In a statement issued by the Bundesfinanzministerium (German Federal Ministry of Finance), Federal Minister of Finance Lars Klingbeil described the proposal as a contribution to reducing bureaucracy and promoting fair competition. He linked this to the objective of ensuring that law-abiding businesses are not placed at a disadvantage compared with businesses that do not record their revenue in full.
Expanded Cash Register Inspections by the Fiscal Authorities
Inspections Also by the Tax Office at the Place of Business Activity
In addition to the new requirements for cash register systems, the bill is intended to expand the fiscal authorities’ inspection powers. Its focus is the Kassen-Nachschau (cash register inspection). It enables an unannounced and timely inspection of tax-relevant matters connected with the proper recording of business transactions.
The inspection may cover both electronic recording systems and open cash boxes. In future, such an inspection is no longer to be conducted exclusively by the Finanzamt (tax office) responsible for taxation. The tax office in whose district the taxpayer carries out their business activity is also to have this authority.
Significance for Mobile Traders
The planned extension particularly affects traders who frequently operate outside the district of the tax office responsible for them. In the Federal Government’s view, inspections by the locally competent tax office cannot always be conducted appropriately and efficiently in such cases.
The additional jurisdiction at the respective place of business activity is primarily intended to facilitate inspections at funfairs, Christmas markets and trade fairs. The fiscal authorities would be able to inspect the records maintained there directly at the place where the business operates.
Stricter Penalties for Manipulating Electronic Cash Registers
The bill also provides for stricter criminal penalties for certain forms of interference with electronic cash register systems. In future, commercially distributing or using manipulation software could be punishable by a fine or imprisonment for up to three years.
The Federal Government justifies the increased sentencing range by reference to the greater degree of criminal intent required to alter cryptographically protected records. The provision is also intended to cover manipulation that prevents the relevant records from being created in the first place.
This is a proposed new statutory provision. The Bundestag has not yet adopted a decision on the bill.
Further Legislative Process
According to the announcement by the Deutscher Bundestag (German Federal Parliament), the bill is on the agenda for Friday, 6 November 2026. Thirty minutes have been allocated for its first reading. The draft legislation is then to be referred to the committees for further deliberation.
In its official explanatory memorandum, the Federal Government cites, in particular, the need to ensure uniform taxation and consistent tax enforcement as the rationale for the proposal. Whether the planned provisions will enter into force, and in what final form, depends on the further legislative process.
Tax Law Assessment of the Planned Requirements
The proposed changes concern both the form in which receipts are provided and the technical design of cash register systems, as well as the fiscal authorities’ inspection powers. As a result, businesses may face new requirements regarding the recording, safeguarding and provision of tax-relevant cash register data. MTR Legal Rechtsanwälte advises businesses on issues relating to these matters as part of its tax law advisory services.
