Germany sends cash-recordkeeping bill to committee

Electronic receipts proposed from 2028

The bill would replace the paper-receipt mandate with an electronic receipt made available to each transaction participant, in a standardised data format and close in time to the transaction, from 1 January 2028. The Finance Committee is leading further scrutiny, so the text and timing may still change.^[1][2]

Turnover and cash thresholds shape scope

Proposed section 146b of the Fiscal Code would require a taxpayer with annual total turnover above EUR 100,000, measured under section 19(2) of the VAT Act, and income from agriculture and forestry, commercial business or self-employment to use an electronic recording system meeting section 146a and the Cash Security Ordinance. The explanation says this includes a certified technical security device and DSFinV-K-format records. Cash and debit or credit-card payments would be captured, while direct debits and transfers through the taxpayer's bank account would be outside this rule. Taxpayers accepting cash would be excluded if annual cash turnover is below EUR 12,000.^[2]

Proposed transition depends on threshold timing

For entities already over the threshold in 2026, the proposed till mandate would apply from 1 January 2028. Where the threshold is first crossed in 2027 or later, the general start would be 1 July of the year after the first excess. The bill would also widen local cash-audit powers where the taxpayer operates the system or conducts the activity, which could affect mobile traders and temporary sales locations outside their home tax district.^[2]

Prepare without treating the bill as law

Groups should identify German branches and subsidiaries with tills, roll up turnover at taxpayer level, test the EUR 12,000 cash exception and ask point-of-sale vendors about certified security devices and standard-format electronic receipts. The proposal creates no new tax-return form or due date. No taxpayer should switch systems solely because of the first reading; monitor committee amendments, passage, promulgation and implementing rules, especially any exceptions and receipt-delivery specifications.^[1][2]