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Information Oberfinanzdirektion Karlsruhe

Information on the regularity of the cash accounting system

The provisions of the German Fiscal Code (AO; in particular §§ 145 to 147 AO in the version of 29.12.2016) apply to the storage of digital documents.

There are also several administrative regulations. These are:

  • BMF letter dated 26.11.2010, BStBl. I 2010, 1342,
  • BMF letter dated 28.11.2019, BStBl. I 2019, 1269, (GoBD - Principles for the proper keeping and storage of books, records and documents in electronic form and for data access).

Companies with cash receipts generally use systems upstream of the accounting system, such as cash registers, scales with cash register function, PC cash register systems and taximeters. These systems are subject to the same record-keeping and record-keeping requirements as the actual accounting systems.

The use of this technology has a number of business advantages, but is also associated with obligations. This leaflet is intended to provide an overview in order to identify and avoid common sources of error in cash accounting.

1. Principle of the obligation to keep individual records (§ 146 Paragraph 1 Sentence 1 AO)

The details are regulated by the Application Decree for the Tax Code (AEAO) on Section 146 AO, BMF letter dated 19.06.2018.

The principles of proper accounting generally require the recording of each individual business transaction - i.e. each operating income and operating expense, each contribution and withdrawal to an extent that enables an expert third party to completely check its basis, its content, its origin and processing and its significance for the business within a reasonable period of time. This means not only recording the monetary consideration, but also the substance of the transaction and the name of the contracting party. See also no. 2.1.5 AEAO to § 146.

In addition, the principle of the obligation to keep individual records is derived from the provisions of turnover tax law in § 22 (1) no. 1 of the Turnover Tax Act (UStG). It applies not only to those who are obliged to keep accounts, but also to taxpayers who determine their profits in accordance with § 4 Paragraph 3 of the Income Tax Act (EStG) (revenue surplus calculators).

The level of detail in which individual records must be kept is derived from § 14, para. 4 UStG. This provision requires, among other things, information in the invoice about

  • Name and address of the recipient of the service,
  • Type of goods or services,
  • quantity sold,
  • Price and
  • Sales tax.

For small-value invoices under EUR 250, see § 14 (6) UStG in conjunction with § 33 UStDV. However, there is no obligation to record each transaction individually (in contrast to recording in the cash register system). If the same type of goods with the same retail price are combined in a group of goods, this is not objected to, provided that the quantity or number sold remains apparent. This applies accordingly to services

Furthermore, the types of payment are to be recorded for each business transaction. Only cash sales are to be recorded in the cash book. Non-cash payments (credit card/ EC sales, etc.) must be recorded separately.

Short-term joint entries of cash and non-cash daily transactions in the cash book are not objectionable only if the non-cash daily transactions originally entered in the cash book are identified separately and are comprehensibly transferred again immediately afterwards from the cash book to a separate account, provided that the cash register is still capable of being overturned (see GoBD, marginal no. 55).

2. Exception to the obligation to keep individual records for reasons of reasonableness (§ 146 Paragraph 1 Sentences 3 and 4 AO)

In the case of sales of goods to a large number of unknown persons against cash payment, the obligation to keep individual records does not apply for reasons of reasonableness if no electronic recording system is used.

The reasonableness considerations underlying the exemption under § 146 (1) sentence 3 AO can in principle also be applied to services. For services, however, individual records must always be kept if the customer contact corresponds approximately to the duration of the service and the customer can usually exert an individual influence on the performance of the service. However, service providers - as well as retailers - cannot rely on the simplification of record keeping insofar as individual records are actually kept (e.g. appointment/table reservations, advance orders, recording of customer data, etc.). - see AEAO to § 146, No. 2.2.6).

If, on the other hand, an electronic recording system is used, the individual recording obligation applies irrespective of whether the electronic recording system is to be protected with a certified technical security device in accordance with § 146a (3) AO in conjunction with the Cash Security Ordinance

If the taxpayer uses an open shop cash register as well as a scale that only displays the weight and/or the price and does not have a memory function beyond the duration of the individual weighing process, it is not objected if the above-mentioned individual data of the scale are not recorded. If, on the other hand, the scales meet the requirements of an electronic cash register, the exemption from the individual recording obligation does not apply to this electronic recording system (Section 146 (1) sentence 4 AO).

3. Use of open shop cash registers

There is no "cash register obligation". It is also permissible to keep an open shop cash register. In the case of open shop cash registers, however, the requirements for proper cash management are associated with a high level of effort. Here, too, the recording of each individual commercial transaction with a sufficient description of the transaction is generally required.

If individual recording in accordance with paragraph 2 is not reasonable, the cash receipts must be proven by means of a so-called cash report.

Even in the case of a cash report, the declared business income must be verifiable as to its completeness and correctness (BFH decision of 13.03.2013 file no. X B 16/12). For the preparation of a cash report, the entire business cash balance including hard cash - irrespective of where the money is kept (e.g. safe money, waiters' hand cash, change, petty cash, etc.) - must be counted daily. The final cash balance must then be arithmetically increased by the withdrawals and expenditures and reduced by the deposits and the initial cash balance, so that the result is the daily receipts (retrograde determination). In the case of several cash registers, the cash reports must be individually assignable and the cash balance must be assignable to the respective cash register

Roundings or estimates are not permitted. A counting protocol is not mandatory (BFH decision of 16.12.2016 X B 41/16), but serves as additional proof of the complete determination of the income. However, if a counting protocol is prepared and used for the determination of income, it must be retained.

The expenses, income, withdrawals and deposits (incl. proof of origin) are to be evidenced by receipts (if applicable, own receipts).

Only a cash report prepared in this manner is admissible and proper.

Tables created with standard software (e.g. Office programs) do not comply with the principle of immutability. Software available on the market is only recognised as proper if a subsequent change is not possible or is marked with an appropriate note.

4. Use of electronic cash registers

Since 1.1.2017 (BMF letter of 26.11.2010, BStBl. I 2010, 1342), only those electronic cash registers may be used that allow complete storage of all tax-relevant data - in particular journal, evaluation, programming and master data change data (e.g. item price changes; user ID) (BFH of 16.12.2014, BStBl. II 2015, 519).

Particularly with regard to this BMF letter, care must be taken to ensure that the above-mentioned information of the cash register system is stored completely and unchangeably in digital form. When switching to a new system, it is recommended to continue to keep the "old cash register"

If programming documents or logs of subsequent program changes are missing, this represents a serious formal accounting deficiency (BFH ruling of 25.03.2015, BStBl. II 2015, 743).

All individual data (journal data, master data, evaluation data and programming data as well as their change data) that arise from the use of the cash register must be available during the retention period of 10 years

  • available at any time,
  • uninterruptedly readable and
  • machine evaluable
  • be stored.

5. Procedural documentation

The procedural documentation for the recording systems used, the associated manuals, operating and programming instructions and the documentation of the operating procedures must be kept available.

6. Data access rights

The tax authorities have the right to access data in accordance with § 147 Paragraph 6 AO with regard to the digital cash register data which must be recorded and kept within the framework of an external audit. Here, within the framework of direct or indirect data access, inspection of the cash register system can be carried out or a transfer of data media can be demanded.

For the transfer of data media, all necessary data must be made available on a machine-readable data medium (e.g. CD, DVD, USB stick). The company itself must therefore ensure that the individual data with all structural information in the cash register is not only stored, but also exported and made available in a format that can be read by the tax office

This also applies to data held by third parties (e.g. data processing centre, cloud).

7. Act to protect against manipulation of basic digital records

On 29.12.2016, the law on protection against manipulation of basic digital records was published (BStBl. 2017 I, p. 21). According to this, there are further requirements for the cash records of an entrepreneur (§§ 146a, 146b AO). Which electronic recording systems must have a certified technical security device (TSE) is regulated by the Cash Security Ordinance (KassenSichV - BStBl. 2017 I, p. 1310).

8. Kassensicherungsverordnung

The above-mentioned law on the protection against manipulation of digital basic records also created the basis for a legal ordinance that specifies the new requirements for electronic cash register records.

The Cash Security Ordinance (BMF v. 26.09.2017, BStBl. 2017 I, S 1310) regulates how the certified technical security device (TSE) must be designed. It basically consists of a security module, a storage medium and a uniform digital interface.

More details on this were described in the BMF letter dated 17.06.2019 (AEAO to § 146a - Ordnungsvorschriften für die Buchführung und für Aufzeichnungen mittels elektronischer Aufzeichnungssysteme)

Security-related details on this are contained in the Technical Guidelines of the Federal Office for Information Security (BSI), significantly TR-03153, TR-03151, TR-03116 and others (

The TSE is mandatory as of 01.01.2020, in exceptional cases as of 01.01.2023 (for transitional arrangements, see the above table on § 146a (1) AO). Non-objection and equity regulations for the later use of a TSE expired on 30.09.2020 and 31.03.2021 respectively (BMF of 06.11.2019, decree FM BW of 10.07.2020). Relief going beyond this is only possible after approval by the tax authorities on individual application in accordance with § 148 AO. The prerequisite for this is that the use of the TSE entails an undue hardship that can be proven in detail. Further information is available on the homepage of OFD Karlsruhe (see 11. Further information). The obligation to issue receipts in accordance with § 146a paragraph 2 AO remains unaffected by this (see no. 9).

It is pointed out that cash register systems which cannot be upgraded with a TSE may no longer be placed on the market from 01.01.2020 (sales ban). PC cash register systems which cannot be upgraded may no longer be used from 01.01.2020.

The notification pursuant to Section 146a (4) AO is to be waived until an electronic transmission option is used. The date of use of the electronic transmission option will be published in the Federal Tax Gazette Part I.

9. Cash inspection (§ 146b AO)

A control instrument of the tax authorities is the cash inspection. It serves to verify the correctness of cash records (cash receipts, cash expenditures). An official can enter the business premises and business rooms unannounced - during normal business and working hours.

Electronic or computer-aided cash register systems, app systems, scales with cash register function, taximeters, odometers, gambling machines and open shop cash registers are subject to the cash register inspection.

During the cash register inspection, data from the electronic recording system may be viewed by the official. Also the transmission of data on a machine evaluable data medium can be required.

Details are regulated in the AEAO to § 146b, BMF letter dated 29.05.2018.

The tax authorities use verification software to check TSE certificates, validate signatures and check and compare cash register data with the TSE data.

With the option of electronic transmission of the notification of TSE use (Section 146a (4) AO), this also enables a quick query to be made as to whether the electronic recording system and the TSE have been properly notified to the tax authorities.

10. Consequences of deficiencies

If the cash management is not in order, this will result in the loss of orderliness of the entire accounting.

11. Further information

Question and answer catalogue on the website of the Federal Ministry of Finance (guidance on § 146a AO)

Leaflet from Oberfinanzdirektion on the obligation to issue receipts

Leafletof the Oberfinanzdirektion to the cash management of the taxi and rented car industry

Homepage of the Oberfinanzdirektion Karlsruhe

Federal Office for Information Security (BSI) FAQ

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