Update of November 6, 2026: The Bundestag (German Federal Parliament) debated the government bill for the Second Cash Register Act at first reading on November 6, 2026, and referred it to the committees for further deliberation. In addition, by letter dated October 26, 2026, the Bundesministerium der Finanzen (German Federal Ministry of Finance) revised the Application Decree on § 146a AO (German Fiscal Code) with regard to DSFinV-K 3.0.
Federal Cabinet adopts bill for the Second Cash Register Act
On September 23, 2026, the Bundeskabinett (German Federal Cabinet) adopted the bill for an “Act on the Further Development of Cash Register Records, the Fight Against Tax Evasion and the Further Digitalization of Records under Commercial and Tax Law.” The initiative, referred to as the Second Cash Register Act, builds on the existing requirements for electronic recording systems.
The planned provisions are intended to further develop cash register records, restrict opportunities for tax evasion and further digitalize record-keeping obligations under tax law and commercial law. The primary focus is on the electronic provision of receipts, the introduction of mandatory electronic cash registers for certain businesses and changes to document retention requirements.
The government bill was submitted to the Bundesrat (Federal Council of Germany) on October 9, 2026, as Printed Paper 585/26 (parliamentary document reference). It was submitted to the Bundestag on November 2, 2026, as Printed Paper 21/8867 of the 21st electoral term. The legislative process has not yet been completed, meaning that the proposed provisions may still be amended.
Digital receipts to replace paper receipts from 2028
Electronic provision as the standard
A key element of the government bill concerns the issuance of receipts. From January 1, 2028, the current obligation to issue paper receipts is generally to be replaced by technology-neutral electronic provision.
One potential technical solution is a QR code in a standardized format. However, customers are not to be required to actually access or accept the electronically provided receipt.
On the occasion of the Cabinet decision, the Bundesministerium der Finanzen explained that the bill is intended to implement the action plan to combat tax and financial crime and the corresponding agreement in the coalition agreement. In this context, Federal Minister of Finance Lars Klingbeil stated that the mandatory paper receipt should be abolished and digital receipts should become the standard.
Paper receipts remain available on request
The proposed transition to electronic receipts does not completely eliminate paper receipts. If a customer continues to request a receipt in paper form, it will still have to be issued.
The receipt requirement will therefore not be abolished altogether. Instead, it will generally be converted into an obligation to provide receipts electronically, while paper receipts will remain available on request.
Mandatory electronic cash registers for certain businesses
Relevant revenue threshold of EUR 100,000
According to the government bill, businesses with total annual revenue exceeding EUR 100,000 will in future be required to use electronic recording systems. The requirement is intended to apply to businesses whose total annual revenue exceeds EUR 100,000.
Within this scope, open cash boxes are to be replaced by electronic cash register systems from 2028. These systems will, in particular, be subject to the requirements of § 146a AO. This generally includes the use of a technical security device to safeguard the underlying digital records.
Commencement of the cash register requirement and proposed exemptions
Under the government bill, the mandatory cash register requirement is generally to apply from July 1 of the year following the year in which the relevant revenue threshold is exceeded. For businesses that already exceed the revenue threshold in 2026, the requirement is scheduled to commence on January 1, 2028.
The acquisition or decommissioning of the electronic recording system and any change to the certified technical security device are to be reported to the competent Finanzamt (German tax office) within one month. Taxpayers whose annual cash revenue is below EUR 12,000 are to be exempt. In addition, a separate ordinance may provide for further exemptions.
Sanctions and measures against manipulation
Fines for breaches of cash register and receipt requirements
The government bill provides for new sanctions for breaches of the planned obligations. The proposed legal consequences differ according to the type of violation:
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A breach of the mandatory cash register requirement may be punished as an administrative offense with a fine of up to EUR 25,000.
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A breach of the obligation to provide a receipt may result in a fine of up to EUR 5,000.
Whether a sanction may be imposed in an individual case depends on the statutory requirements and the circumstances of the particular matter.
Different penalties for manipulation software
The bill also introduces a new tax offense relating to manipulation software affecting electronic recording systems. The statutory wording distinguishes between placing such software on the market and using it.
Anyone who, contrary to § 146c(2) AO-E (draft German Fiscal Code), places a recording system, software program or software component on the market is to be punished under § 374a(1) AO-E by imprisonment for up to five years or a fine. By contrast, § 374a(2) AO-E provides for imprisonment for up to three years or a fine for the use of manipulation software.
In addition, the powers of the tax authorities to conduct their own investigations into the falsification of technical records are to be expanded where electronic recording systems are involved.
Expansion of cash register inspections
New provision in § 146d AO-E
The government bill transfers cash register inspections to a new § 146d AO-E and expressly expands the tax authorities’ inspection powers. In future, the power to conduct a cash register inspection is not to be limited to the tax authority competent under §§ 18 to 21 AO. Any tax authority in whose district the taxpayer uses an electronic recording system, maintains records of cash receipts and cash expenditures or carries out a corresponding activity is also to be authorized to conduct such an inspection.
If another Finanzamt conducts the cash register inspection, it must notify the Finanzamt competent under §§ 18 to 21 AO of the results. The provision is intended to enable cash register inspections to be conducted across different authorities’ jurisdictions.
Further digital record-keeping obligations
Odometers for rental cars and pooled on-demand transport
The government bill also includes a tax-law requirement to use an odometer with a digital interface and a connection to a technical security device. This is intended to ensure equal treatment of taxis and rental cars for tax record-keeping purposes.
This obligation is to apply to rental cars and vehicles used for pooled on-demand transport from 2029. The scope of digital record-keeping obligations would thus be expanded beyond conventional cash register transactions.
Digitalization of retention under commercial and tax law
Electronic retention of financial statements and opening balance sheets
The government bill also contains amendments concerning the digital retention of financial statements and opening balance sheets. An amendment to § 257(3), sentence 1 HGB (German Commercial Code) is intended to make it possible to retain these documents as reproductions on image or other data carriers, provided that the reproduction visually corresponds to the original and is available at all times.
Opening balance sheets and annual financial statements prepared solely for tax purposes will likewise no longer necessarily have to be retained in paper form. An amendment to § 147(2) AO is proposed for this purpose.
Reduction in compliance costs and transition costs
The ministerial draft dated August 7, 2026, estimated an annual reduction in compliance costs for businesses of approximately EUR 88.89 million. At the same time, it estimated one-off compliance costs of approximately EUR 98.748 million.
The Zentralverband des Deutschen Handwerks considers the proposed commencement date of January 1, 2028, to be too soon and calls for the mandatory cash register requirement to be coordinated in advance with the technical requirements for cash register systems and the rules governing electronic invoicing. By contrast, the association considers the exemption for cash revenue below EUR 12,000 to be an appropriate approach.
The association also questions the estimated level of compliance costs and points to potential acquisition and follow-up costs associated with the electronic provision of receipts. These comments relate to a government bill whose content may still be amended during the further legislative process.
New BMF letter on DSFinV-K 3.0
Revision of the Application Decree on § 146a AO
By letter dated October 26, 2026, the Bundesministerium der Finanzen revised the Application Decree on § 146a AO. The revision was prompted in particular by the new version of the Digital Interface of the Tax Authorities for Cash Register Systems, DSFinV-K 3.0.
The revised Application Decree is generally to apply with effect from January 1, 2029. If DSFinV-K 3.0 is used before that date in accordance with the transitional provision contained therein, the version of the Application Decree on § 146a AO applicable from January 1, 2029, must also be applied ahead of schedule.
The letter describes the future requirements for electronic or computerized cash register systems and cash registers. It must be distinguished from the parliamentary legislative process concerning the Second Cash Register Act.
Status of the legislative process
First reading in the Bundestag completed
The Bundestag debated the government bill at first reading on November 6, 2026. Thirty minutes were allocated for the debate. The bill was subsequently referred to the committees for further deliberation, with the Finanzausschuss (Bundestag Finance Committee) serving as the lead committee.
No final decision on the Second Cash Register Act has yet been made. The proposed provisions on mandatory cash registers, the provision of receipts, cash register inspections and sanctions may still be amended during the further parliamentary process.
Significance for businesses conducting cash transactions
The planned provisions particularly affect businesses that conduct cash transactions, use open cash boxes or have previously issued paper receipts. The government bill combines the electronic provision of receipts with a revenue-based mandatory cash register requirement, expanded inspection powers and additional sanctions.
For businesses in retail, hospitality, services and other cash-intensive sectors, the proposed amendments may have significant organizational and tax-law implications. However, only the final version of the legislation following completion of the parliamentary process will be decisive.
MTR Legal Rechtsanwälte advises businesses, investors and high-net-worth individuals on domestic and cross-border matters relating to cash register records, digital receipts and retention obligations under tax law. MTR Legal’s tax law advice provides an assessment of the planned provisions tailored to the circumstances of each individual case.
