Cash register inspection in Germany – RetailForce Software GmbH

Since 1 January 2018, the auditors of the Federal Ministry of Finance (BMF) and the local tax offices have regularly carried out so-called "cash register inspections" ("Kassen-Nachschau"). The regularity of the records in the (registration) cash register system is checked. The audits take place without prior notice and are also carried out outside of a so-called external audit (= overall audit of tax-relevant facts of a taxable company) [2].

Within the framework of a cash register inspection, the representatives of the tax administration are entitled to enter the company's business premises during normal business and working hours. If work is already being done or is still being done outside of these hours, they may also do so at these times. During the cash inspection, however, the auditors have no right to search. Of course, the auditor must identify himself [5].

What is being inspected?

The cash register inspection checks whether the following facts are complied with:

Is the "technical security device" (TSE - "Technische Sicherheitseinrichtung") available and is it used properly? (§ 146a AO + KassenSichV) [1], [4].
Is the obligation to issue receipts fulfilled? (§ 146a Abs. 2 AO)
Propriety of the data (KassenSichV).

How is audited and what needs to be provided?

Covert audit

During a covert audit, the inspector does not reveal his identity at first. Like a normal customer, he purchases a product or service from the company. In this way, it is to be determined whether the company, in accordance with the legal requirements, fulfils the obligation to issue receipts and whether the data are processed via a certified technical security device, for example by the auditor scanning the QR code on the receipt (contains TSE data).

Data verification

The financial auditors also have the right to inspect the data of the electronic recording system ("cash register"). This is where the so-called uniform digital interface comes into play. The data must be regularly made available in the prescribed export format (DSFinV-K format).

If the RetailForce Cloud Archive is used for archiving the cash register records, these can be exported from the RetailForce Cloud. See the article below for instructions on how to export data: Data export for cash register audit Germany.

In the course of a cash register audit, records, books as well as other organisational documents relevant for cash management are audited for a certain period of time, therefore the following documents must be submitted:

the current cash register records,
historical cash records, over the entire period of the statutory retention period (10 years - § 147 Abs. 3 AO [3]), this also applies to cash registers that have been shut down / decommissioned,
procedural documentation ("Verfahrensdokumentation") (operating instructions, programming instructions and data collection protocols on programme changes carried out),
Furthermore, the auditor may demand that a z-report / cash register closing is being carried out during the audit.

Furthermore, it should be noted that if complaints are raised in the course of the cash audit, an external audit may be carried out: Cf. § 146b para. 3: "If the findings made during the cash audit give cause for this, an external audit pursuant to § 193 may be carried out without a prior audit order."