Germany Mandates Electronic Cash Registers and Digital Receipts from 2028

Context

Germany's proposed legislation marks a significant shift in its approach to point-of-sale tax compliance and cash-transaction transparency. The draft law, approved by the federal cabinet on October 9, 2026, targets implementation in 2028. This development is distinct from recent tax-digitization efforts focused on transfer pricing documentation and BZSt portal security, instead addressing the modernization of cash-register systems—a trend observed in several EU member states.

The policy rationale behind this initiative is twofold: modernizing tax record-keeping infrastructure and reducing the opacity associated with cash transactions. Historically, cash transactions have been a vector for VAT and income-tax underreporting in the retail and hospitality sectors. By mandating electronic cash-register systems and digital receipts, Germany aims to enhance transparency and reduce the scope for fraud.

What's Changing

The draft law stipulates that businesses with annual turnover exceeding €100,000 must replace open cash boxes with certified electronic cash-register systems. This requirement does not apply to taxpayers whose annual cash turnover falls below €12,000, providing relief for very small or cash-light operators. From 2028, digital receipts will become the default, significantly reducing the volume of paper receipts currently generated at point of sale.

As of October 11, 2026, the draft law is two days old and has not yet entered parliamentary consideration. It must pass the full German legislative process before becoming law. No timeline for parliamentary debate or committee review has been publicly announced. The 2028 implementation date and the €100,000/€12,000 thresholds remain the stated targets but are subject to change during legislative passage.

Implications for Retail and Hospitality Sectors

The proposed legislation will have significant implications for businesses operating in the retail and hospitality sectors. Companies with annual turnover exceeding €100,000 will need to invest in certified electronic cash-register systems and adapt their operations to comply with the new requirements. This includes training staff on the use of digital receipts and ensuring that all transactions are recorded electronically.

For very small businesses with cash turnover below €12,000, the exemption provides some relief. However, these businesses may still benefit from adopting electronic cash-register systems to streamline their operations and enhance transparency. The reduction in paper receipts will also have environmental benefits, aligning with broader sustainability goals.

Outlook and What to Watch

The draft law's passage through the German legislative process will be a key development to watch. Changes to the proposed thresholds or implementation timeline are possible during parliamentary debate and committee review. Businesses should monitor these developments closely to ensure compliance by the targeted 2028 deadline.

Additionally, the impact of this legislation on multi-jurisdiction retail and hospitality operations that include Germany will be significant. Companies operating across several EU member states may need to adapt their systems and processes to comply with varying requirements. The downstream implications of this legislation, particularly in terms of fraud reduction and tax compliance, will also be an area of interest for policymakers and businesses alike.