Which electronic recording systems are subject to reporting?
- Computerized/PC cash register systems
- Tablet/app cash register systems
- Electronic cash registers
- Taximeters
- Odometers
With regard to the definition of electronic recording systems, please refer to the Application Decree to the Fiscal Code (AEAO) on Section 146a, paragraph 1.2 (definition of cash register (systems)), paragraph 1.3 (definition of EU taximeters) and paragraph 1.4 (definition of odometers).
What submission options are available for the notification obligation in accordance with Section 146a (4) AO?
From 01.01.2025, the notification can be submitted to the tax authorities as follows
- by direct entry in the ELSTER form "Notification procedure in accordance with Section 146a (4) AO",
- by uploading an XML file to www.elster.de in MY ELSTER or
- by data transfer from software via the ERiC interface.
By when must the first notification be submitted at the latest?
The data for electronic recording systems purchased before 01.07.2025 must be submitted by 31.07.2025 at the latest.
The data for all electronic recording systems purchased after 01.07.2025 must be reported within one month of purchase.
Systems that no longer exist on July 1, 2025 are not subject to the reporting obligation under Section 146a (4) AO.
The current systems at the time the electronic transmission option is used are relevant.
What must be observed?
One notification must be submittedper permanent establishment. For each notification, all electronic recording systems of a permanent establishment must always be transmitted in the uniform notification (so-called "gross method" - number 1.16.1.4 of the AEAO on Section 146a AO). Each electronic recording system must always be assigned to only one permanent establishment within the meaning of Section 12 AO. If there are several permanent establishments, a separate notification must be submitted for each individual permanent establishment. In the event of a correction or adjustment (e.g. due to the acquisition, decommissioning or change of the permanent establishment of an electronic recording system), updated notifications must be submitted for the affected permanent establishments.
More on the reporting obligation:
Further detailed information, answers to frequently asked questions (FAQ) and instructions for completing the form with a detailed overview of the required fields can be found on the BMF website.
BMF website
- BMF letter dated June 28, 2024
- FAQ of the Federal Ministry of Finance
- Completion instructions for the notification of electronic recording systems
Legal basis