TSE obligation at the card terminal: what the KassenSichV really requires

The short answer

A pure card terminal needs no TSE. Under section 146a(1) of the Abgabenordnung, what is covered is recording business transactions with an electronic recording system — and a device that only authorises payments is not one. As soon as a till app runs on the same device, the classification flips: then it is a till system, and a whole chain of duties hangs on that.

This is the most common misconception in sales conversations, and it goes both ways: one seller adds a TSE to the terminal that nobody needs, the next ships a SmartPOS with a till function and says not a word about the notification duty.

Payment terminal or till system: where the line runs

Section 1(1) KassenSichV defines electronic recording systems as “electronic or computer-based till systems or registered tills” and expressly excludes six groups of device: ticket machines and ticket printers, pay-and-display and parking ticket machines used in parking management together with charge points for electric and hybrid vehicles, electronic bookkeeping programs, goods and services vending machines, cash machines, and money and merchandise gaming machines (statutory text re-read today).

The card terminal appears on neither of these lists — neither the covered one nor the excluded one. Which is why it is not the casing that decides but the function.

Setup	What the device does	TSE, receipt, notification?
Terminal next to the till, connected by a till interface	authorises the payment, receives the amount from the till	no — the duties hang on the till
Terminal alone, amounts typed in manually	authorises the payment, records no business transactions	no — recording then runs through the open cash drawer
SmartPOS with till app, products, order entry	till and terminal in one casing	yes, in full
Smartphone till app plus card reader or Tap to Pay	till on the phone	yes — the app is the recording system

How till and terminal come together technically is in my article on till integration via ZVT, O.P.I. and cloud. For the tax question only one thing counts: whatever enters the orders is the till.

The chain of duties, once the device is a till

Duty	Legal basis	What has to be done in concrete terms
Certified technical security device	section 146a(1) sentences 2 and 3 AO	security module, storage medium and a uniform digital interface — as hardware or cloud TSE
Issuing a receipt	section 146a(2) AO	make a receipt available in immediate temporal connection with the business transaction
Mandatory details on the receipt	section 6 KassenSichV	seven items, legible or in a QR code or in an electronic invoice under section 14(1) UStG
Notification to the tax office	section 146a(4) AO	eight items, electronically, within one month of acquisition or decommissioning

Two details that regularly go wrong in practice. First, the receipt: the seven mandatory items include, among other things, the transaction number, the serial numbers of the recording system and the TSE, and the check value and continuous signature counter. The payment slip printed by the terminal has none of that. Anyone mistaking the customer's card payment slip for the till receipt is meeting neither duty properly. Since the Second Regulation amending the Kassensicherungsverordnung (executed on 14 January 2026, promulgated in Bundesgesetzblatt I no. 10 of 19 January 2026), the receipt content may also sit inside an electronic invoice — the items themselves remain the same.

Second, the notification: it relates to the place of business, and according to ELSTER “all electronic recording systems of a place of business must always be transmitted in the unified notification with every notification” (elster.de, retrieved on 18 September 2026). Anyone retrofitting a second device therefore re-notifies the entire site. According to the Federal Ministry of Finance the procedure has been available since 1 January 2025; for systems acquired before 1 July 2025 the deadline expired on 31 July 2025 (BMF circular of 28 June 2024).

What the TSE costs — and how that spreads over the ticket

The TSE is either bought as hardware or rented as a cloud service. For hospitality packages REA Card states a hardware TSE at 399.90 euros one-off and a cloud TSE at 14.90 euros a month (rea-card.de, retrieved on 18 September 2026). Tillhub quotes “POS Go from €30 per month including TSE” (tillhub.de, retrieved on 18 September 2026), and PayPal writes for the point-of-sale app: “You can use our GoBD- and KassenSichV-compliant software with no monthly fee” (zettle.com, retrieved on 18 September 2026).

Work that down onto the ticket, not onto the month. The following model calculation takes the cloud TSE at 14.90 euros and spreads it over the number of tickets that arises at each ticket size:

Business	Ticket size	Monthly turnover	Tickets per month	TSE per ticket	Share of the ticket
Bakery	€4.50	€8,000	around 1,780	0.84 ct	0.19 %
Snack bar	€12.00	€12,000	1,000	1.49 ct	0.12 %
Hairdresser	€45.00	€18,000	400	3.73 ct	0.08 %
Restaurant	€90.00	€45,000	500	2.98 ct	0.03 %

Unlike the merchant discount rate, the TSE therefore hits the small ticket hardest in percentage terms — but in each of the four cases it stays below a tenth of what a fixed per-transaction fee of eight or nine cents per payment amounts to. The TSE is rarely the expensive item. What gets expensive is the till around it.

And the fundamental buy-or-rent question answers itself arithmetically here: 399.90 euros divided by 14.90 euros is around 27 months. Anyone planning for longer than a good two years does better with the hardware — provided the module's certification lasts that long. That is exactly what belongs asked before signing: how long is this TSE certified for, and what happens afterwards?

What is inspected, and what it costs when it is missing

The cash register inspection under section 146b AO allows officials to enter business premises “without prior announcement and outside an external audit, during normal business and working hours”; it expressly extends to checking the proper use of the recording system. Where the records exist electronically, transmission via the uniform digital interface may be demanded — at the taxpayer's expense. If the findings give cause, the inspection may move to an external audit without an audit order.

The range of fines is in section 379 AO: anyone who does not use such a system, does not use it correctly or does not protect it correctly is committing an administrative offence — up to 25,000 euros under paragraph 6. Paragraph 1 sentence 1 no. 6 is notable: it is also an offence to advertise or place such a system or such software on the market commercially. That provision is addressed not to the merchant but to us providers. Anyone selling you a till solution without a certified TSE is taking that risk themselves — a good reason to ask the question directly.

The planned mandatory till: what is a draft and what is not

Today the position is: there is no obligation to operate an electronic till at all. The open cash drawer remains permissible; section 146a AO only bites on those who use an electronic recording system.

That is set to change. On 7 August 2026 the Federal Ministry of Finance published the draft bill of an “Act on the introduction of a mandatory till, on combating tax evasion and on the further digitalisation of tax and commercial law”, together with a discussion draft of a regulation on exemptions from the mandatory till. It provides for a mandatory till from 100,000 euros of annual turnover, plus the complete abolition of the paper receipt obligation on 1 January 2028, to be replaced by an obligation to make a receipt available; exemptions in hardship cases are to be governed by a statutory instrument. That is a draft from the ministry, not an enacted law — thresholds, deadlines and exemptions may still shift in the process. Anyone signing today should nevertheless reckon with it. The same separation between intention and law in force applies to mandatory card acceptance in 2027.

What to do now

1. Check the function first, not the device: does an app run on your terminal in which products or amounts are entered? Then it is a till.
2. Have it put in writing which TSE is installed or booked, how long it is certified for and what the changeover costs afterwards.
3. Compare hardware and cloud TSE against your planned useful life — at the prices given above the line is at around 27 months.
4. Check a real till receipt against the seven mandatory items of section 6 KassenSichV. The terminal slip does not count towards them.
5. Notify every system under section 146a(4) AO within one month — and remember that the notification always covers the complete place of business.
6. If your turnover is above 100,000 euros and you are planning a new terminal anyway: factor the planned mandatory till into the decision on the term, instead of investing twice.

This is the legal position with its sources, not advice for your individual case. What applies to your business is a matter for your tax adviser — but you go into that conversation with the right questions.