Kassenpflicht ab 100.000 Euro: Was der Gesetzentwurf vorsieht

Germany currently follows an unusual principle: anyone taking cash is not required to have a till. The open cash drawer, effectively a till box with a handwritten daily cash report, is permitted. That is set to end. On 7 August 2026 the Federal Ministry of Finance published a ministerial draft introducing a genuine till requirement from 100,000 euros in revenue. The same package also contains the end of the paper receipt obligation. Here is what the draft says, what is still open, and what you should clarify now.

What the ministry has put forward

The draft is titled "Entwurf eines Gesetzes zur Einführung einer Kassenpflicht, zur Bekämpfung von Steuerhinterziehung sowie zur weiteren Digitalisierung des Steuer- und Handelsrechts" (draft act introducing a till requirement, combating tax evasion, and further digitalising tax and commercial law). It was published on the ministry's website on 7 August 2026, and the consultation with associations is under way. The bill implements a commitment from the coalition agreement, which expressly names a till requirement from 100,000 euros in revenue.

An important qualification: this is a ministerial draft, the earliest stage of the legislative process. The cabinet decision, the Bundestag, and the Bundesrat are all still to come. Changes are the rule, not the exception. The direction, however, is clear, and for cash-intensive businesses it is significant.

The core: the new till requirement in § 146b AO

The till requirement is to be placed in the Fiscal Code as a new provision, § 146b AO. The existing principle in § 146 (1) AO, under which cash receipts must be recorded daily but the form of the till is left open, would thereby be broken for part of the business population.

Businesses with revenue from 100,000 euros are to be covered. Anyone below that may continue to work with an open cash drawer. The draft also provides two escape valves:

• an exemption in individual cases where the till requirement would cause objective hardship
• the option of setting general exemptions by statutory instrument. To that end, the ministry has published a parallel discussion draft of a till requirement exemption regulation (KassenPflAusnV).

At which reference date and for which financial year the 100,000 euros are measured, and from when the obligation actually applies, is not yet conclusively settled in the published material. Figures circulating in the trade press cannot currently be substantiated from the ministry's documents. We will update this once the government draft is available.

What a till requirement means in practice

Anyone already using an electronic recording system within the meaning of § 146a AO knows the requirements. For everyone else they are new. A compliant till essentially has to bring three things:

• A certified technical security device (TSE): every transaction is logged and signed so that it cannot be altered. Without a TSE an electronic till system is not fit for use.
• Individual recording: every transaction is captured individually, not just the daily total.
• A digital interface (DSFinV-K): the auditor must be able to export the till data in a standard format. In a cash inspection this is the first thing they reach for.

On top of that comes the notification duty under § 146a (4) AO: electronic till systems must be reported to the tax office via the ELSTER portal, as must acquisition and decommissioning. Anyone acquiring a system now has that obligation from day one.

Budget realistically: for a simple TSE-capable till solution you should expect a low to mid four-figure amount for the initial setup, depending on sector and functionality, plus ongoing costs for the TSE certificate, maintenance, and updates. The purchase is a business expense; at a net price of up to 800 euros it can even be written off immediately in full as a low-value asset under § 6 (2) EStG.

The end of the paper receipt obligation

The second major point in the draft is likely to go down well in practice. The paper receipt obligation is to be abolished entirely on 1 January 2028 and replaced by an obligation to make a receipt available.

The receipt obligation introduced in 2020 under § 146a (2) AO has produced mountains of till roll that nobody wanted: the customer does not take the receipt, the business still has to print it. In future it should be enough to provide the receipt, for example digitally via QR code, app, or email. The receipt does not disappear, but the compulsion to print it does.

For businesses this means: anyone thinking about a new till now should make sure it can issue receipts digitally. From 2028 that will no longer be a convenience feature but the norm.

Sharper tools against till manipulation

The third element gets less attention but matters for audit practice. The draft extends the investigative powers of the tax authorities where technical records are falsified, specifically the data to be logged under § 1 KassenSichV. A notification duty and a fine provision are also envisaged.

The background is well known: manipulation software, so-called zappers, that removes turnover from the till system after the fact. The TSE makes this technically difficult but not impossible. The legislator is closing the gap.

What you should do now

Even though the act is not yet in force, three steps are worth taking regardless of how the process unfolds:

1. Check your revenue. If you are well above 100,000 euros and still working with an open cash drawer, you will very probably fall under the obligation. If you are just below it, watch the process, in particular the question of which period will be decisive for the threshold.
2. Assess your cash bookkeeping honestly. An open cash drawer is permitted, but it is the most demanding form of cash bookkeeping: a daily cash report, arithmetical determination of daily takings, and the ability to reconcile the till at any moment. If that is not running cleanly, it is already an estimation risk under § 162 AO today, with no new law required.
3. If you are buying anyway, buy right. If a new till is due regardless, choose one with a TSE, DSFinV-K export, and digital receipt issuance. That prepares you for all three elements of the draft and already meets today's requirements for an electronic recording system.

Till, receipts, bookkeeping: all from one source

A properly run till is only half the job. The other half is making sure the till data lands cleanly in your accounts, is reconciled monthly, and is complete when a cash inspection comes. That is exactly what Buchführungsheld does for you: real bookkeepers handle your ongoing accounts, integrate your till data, and tell you when something is missing before the auditor does. All digital, all at a fixed price. If you are unsure whether your cash bookkeeping would hold up, book a free initial consultation and we will look at your situation together.

Frequently asked questions

Is there already a statutory till requirement in Germany?

No. There is currently no obligation to use an electronic till. The open cash drawer is permitted, provided the cash bookkeeping is proper. Anyone who does opt for an electronic till system must equip it with a certified technical security device under § 146a AO and report it to the tax office.

From what level of revenue is the till requirement supposed to apply?

The ministerial draft of 7 August 2026 names a threshold of 100,000 euros in revenue, as set out in the coalition agreement. The period over which that revenue is measured and the date from which the obligation applies are not yet conclusively settled in the published material.

Is the receipt obligation being abolished?

Under the draft, the obligation to issue a paper receipt would cease entirely on 1 January 2028 and be replaced by an obligation to make a receipt available. A receipt must therefore still be obtainable, but no longer necessarily printed.

Do I have to report my till to the tax office?

Yes, if it is an electronic recording system within the meaning of § 146a AO. The notification is made electronically via the ELSTER portal and covers acquisition and decommissioning as well. There is no notification duty for an open cash drawer.

What happens if my cash bookkeeping is faulty?

Formal defects in cash bookkeeping can lead the tax office to reject the evidential value of your accounts and to estimate the tax base under § 162 AO. In cash-intensive sectors this is regularly the most expensive part of a tax audit, whether or not a till requirement exists.