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Notifying a German till system (§ 146a AO)

Anyone recording transactions subject to record-keeping duties with the help of an electronic recording system must notify the competent tax office, in the officially prescribed data format by remote data transmission, which system they use (§ 146a(4) sentence 1 AO) — and that notification is due WITHIN ONE MONTH of acquisition OR of taking the system out of service (§ 146a(4) final sentence AO). The duty therefore runs both ways: retiring a till is as notifiable as buying one. The system itself must record every transaction individually, completely, correctly, in good time and in an orderly manner, and be protected by a CERTIFIED TECHNICAL SECURITY DEVICE (§ 146a(1) sentences 1 and 2 AO).

Up to date for 2026 — verified on September 22, 2026Official procedure, no printed formGuide: about 20 min

Deadlines

One month after ACQUISITION of the electronic recording system
§ 146a(4) final sentence AO
One month after TAKING IT OUT OF SERVICE
The same provision — notifying a discarded system is the step most often forgotten
Receipt issuing: in immediate temporal connection with the transaction
§ 146a(2) sentence 1 AO — not a deadline in days but a requirement of simultaneity

Documents to prepare

  • ELSTER access with a certificate or an ELSTER business account
  • The taxpayer's name and tax number
  • Type, number and serial number of each electronic recording system in use
  • Type and serial number of each certified technical security device
  • The date each system was acquired
  • On a replacement: the date the old system was taken out of service
  • The address of the establishment where the system is used
See the procedure on the official site

No form is attached to this procedure: the link leads to the official page that describes it.

What this page gives you

The guide above and the link to the official site. ActioFin does not produce any document for this page: whatever you fill in or file is done on the official medium.

Who this applies to

  • Anyone recording transactions subject to record-keeping duties, or other operations, with the help of an electronic recording system (§ 146a(1) sentence 1 AO) — typically hospitality, retail, hairdressing and beauty businesses
  • Anyone ACQUIRING such a system: the one-month period runs from acquisition (§ 146a(4) final sentence AO)
  • Anyone TAKING such a system OUT OF SERVICE: the same provision names both events on the same footing, and the notification expressly requires the date it was taken out of service (§ 146a(4) sentence 1 no. 8 AO)
  • Manufacturers and dealers in such systems: it is prohibited to advertise commercially, or place on the market commercially, systems, software and security devices that do not meet the requirements (§ 146a(1) sentence 5 AO)
  • Not concerned: anyone recording takings without an electronic recording system — the provision attaches to the USE of such a system, not to the level of cash turnover

Worked example

Café Morgenrot in Kassel replaces its till in March 2026

The owner, Deniz Arslan, brings a new till system into service on 9 March 2026 and retires the old one the same day. He knows the new till has to be notified; that the old one does too is news to him. § 146a(4) AO requires both: the notification is due within one month of acquisition OR of taking the electronic recording system out of service, and the particulars to be notified expressly include the date the system used was taken out of service. Both notifications are therefore due by 9 April 2026 through ELSTER, in the officially prescribed data format by remote data transmission (§ 146a(4) sentence 1 AO). Two further points hang on the same provision. First, the new system must be protected by a certified technical security device consisting of a security module, a storage medium and a uniform digital interface (§ 146a(1) sentences 2 and 3 AO); compliance must be evidenced by a certification of the Federal Office for Information Security which is to be maintained ON AN ONGOING BASIS (§ 146a(3) AO). Second, Deniz must issue each guest a receipt in immediate temporal connection with the transaction and make it available to them (§ 146a(2) sentence 1 AO). Exemption is possible on sales of goods to a large number of unknown persons, but only under § 148 AO, on grounds of reasonableness, in the proper exercise of discretion — and it can be revoked (§ 146a(2) sentences 2 and 3 AO).

How to fill it in, step by step

  1. Establish whether you use an electronic recording system within § 146a(1) sentence 1 AO at all — the duty attaches to use, not to any turnover threshold.
  2. On purchase, check that the system is protected by a certified technical security device consisting of a security module, a storage medium and a uniform digital interface (§ 146a(1) sentences 2 and 3 AO).
  3. Obtain evidence of the Federal Office for Information Security certification and note that it must be maintained on an ongoing basis (§ 146a(3) AO).
  4. Record the date of acquisition and, on a replacement, the date the old system was taken out of service — each starts its own one-month period.
  5. Log in to Mein ELSTER and select the notification concerning electronic recording systems under § 146a(4) AO.
  6. Enter the taxpayer's name and tax number and the particulars of each system and each security device, including the dates.
  7. Transmit the notification in the officially prescribed data format by remote data transmission (§ 146a(4) sentence 1 AO) — within one month.
  8. Set up receipt issuing so that each participant receives the receipt in immediate temporal connection with the transaction (§ 146a(2) sentence 1 AO).
  9. Secure the digital records on the storage medium and keep them available by electronic retention for inspections and audits (§ 146a(1) sentence 4 AO).

Good to know

  • The requirement on the recording itself is fivefold and sits in a single sentence: individually, completely, correctly, in good time and in an orderly manner (§ 146a(1) sentence 1 AO).
  • The certified technical security device is defined by statute and consists of THREE parts: a security module, a storage medium and a uniform digital interface (§ 146a(1) sentence 3 AO).
  • The Federal Office for Information Security certification must be maintained ON AN ONGOING BASIS (§ 146a(3) AO) — it is not a one-off stamp at the point of purchase.
  • The receipt duty applies 'without prejudice to other statutory provisions' (§ 146a(2) sentence 1 AO): it sits alongside the VAT invoicing rules, it does not replace them.
  • Exemption from issuing receipts is conceivable only on sales of goods to A LARGE NUMBER OF UNKNOWN PERSONS, under § 148 AO and on grounds of reasonableness, and it can be revoked (§ 146a(2) sentences 2 and 3 AO).
  • The prohibition in § 146a(1) sentence 5 AO is addressed to the market: non-compliant systems, software and security devices may not be advertised commercially or placed on the market commercially.
  • The digital records must be kept available for inspections AS WELL AS audits (§ 146a(1) sentence 4 AO). The cash inspection is a procedure of its own: officials may enter business premises WITHOUT PRIOR NOTICE and OUTSIDE an audit during usual business and working hours, and it extends to checking the proper use of the electronic recording system (§ 146b(1) sentences 1 and 2 AO).
  • During a cash inspection the official may require data to be transmitted through the UNIFORM DIGITAL INTERFACE or provided on a machine-readable medium — and the taxpayer bears the cost (§ 146b(2) sentences 2 and 3 AO). That is the practical reason the interface forms part of the statutory definition of the security device.
  • The relief under § 148 AO, to which § 146a(2) sentence 2 AO refers for receipt issuing, requires that compliance causes HARDSHIP and that taxation is not impaired by the relief; it can be granted retrospectively and revoked (§ 148 AO).

Common mistakes

  • Notifying only the new till. § 146a(4) AO names acquisition AND taking out of service, and expressly requires the date the system used was taken out of service.
  • Counting the month from the dealer's invoice date. It runs from the acquisition or the taking out of service of the system (§ 146a(4) final sentence AO).
  • Checking the certification only at the point of purchase. It must be maintained on an ongoing basis (§ 146a(3) AO).
  • Limiting receipts to customers who ask. The receipt must be issued AND made available in immediate temporal connection with the transaction (§ 146a(2) sentence 1 AO).
  • Treating exemption from the receipt duty as a given. It presupposes sales to a large number of unknown persons, is granted in the proper exercise of discretion, and is revocable (§ 146a(2) sentences 2 and 3 AO).
  • Assuming small businesses are excluded. § 146a(1) sentence 1 AO attaches to the USE of an electronic recording system, not to size.
  • Leaving the records only on the till. They must be secured on the storage medium and kept available by electronic retention for inspections and audits (§ 146a(1) sentence 4 AO).

Frequently asked questions

When must I notify the till?

Within one month of acquiring the electronic recording system or of taking it out of service (§ 146a(4) final sentence AO). Both events start the period.

Do I also have to notify a till I have scrapped?

Yes. § 146a(4) AO names taking out of service expressly alongside acquisition, and the particulars to be notified include the date the electronic recording system used was taken out of service.

What is a certified technical security device?

It protects the recording system and the digital records and must consist of a security module, a storage medium and a uniform digital interface (§ 146a(1) sentences 2 and 3 AO). Compliance must be evidenced by a certification of the Federal Office for Information Security which is to be maintained on an ongoing basis (§ 146a(3) AO).

Do I really have to give every customer a receipt?

Yes. Anyone recording transactions subject to record-keeping duties must issue a receipt to the participant in immediate temporal connection with the transaction and make it available to them (§ 146a(2) sentence 1 AO).

Can I be exempted from issuing receipts?

Only in limited circumstances. On sales of goods to a large number of unknown persons the tax authorities may grant exemption under § 148 AO on grounds of reasonableness in the proper exercise of discretion; the exemption can be revoked (§ 146a(2) sentences 2 and 3 AO).

How must the system record?

Every transaction subject to record-keeping duties and every other operation individually, completely, correctly, in good time and in an orderly manner (§ 146a(1) sentence 1 AO).

Go further

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Official sources

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Guide and document provided for information purposes only; they do not constitute personalised legal or tax advice. Check the recipient organisation's requirements and consult a professional if needed.