Cash Receipt or E-Invoice? What the 2026 KassenSichV Amendment Really Means

Since February 1, 2026, an e-invoice can take over the function of a cash register receipt — a separate receipt under Section 146a(2) of the German Fiscal Code (AO) is then no longer required. But this only applies if the e-invoice is generated by the till system itself. If a downstream system creates the invoice instead, the simplification does not apply. For most businesses with B2B cash sales, day-to-day practice therefore changes very little.

What the 2026 KassenSichV amendment actually regulates

The Second Ordinance Amending the Cash Register Security Ordinance (KassenSichV) was issued on January 14, 2026 and published in the Federal Law Gazette (BGBl. I 2026, No. 10), with the substantive changes taking effect on February 1, 2026. Its core is the new Section 6 sentence 2 no. 3 KassenSichV: the receipt data a till must generate anyway under Section 6 sentence 1 KassenSichV may be incorporated into an e-invoice sent to the customer. The e-invoice then takes over the receipt function, instead of a separate cash receipt having to be issued in addition.

That sounds like a meaningful simplification for any business selling for cash to business customers — hardware stores, workshops, hospitality serving corporate clients, trade businesses at the counter. Much of the coverage frames the rule as if e-invoices now "replace the cash receipt outright." That framing goes too far.

Why the simplification rarely applies where it would matter most

The exception only works if the till itself issues the e-invoice — not a downstream system. The German Confederation of Skilled Crafts (ZDH) guidance on cash management states this explicitly: an e-invoice generated by a downstream system is not covered by Section 6 sentence 2 no. 3 KassenSichV. The combined receipt-and-invoice function must therefore already originate at the till itself, in real time, at the point of sale.

In practice, this means a bookkeeping or documentation system that collects, checks and books receipts afterward — i.e. operates downstream — cannot create this simplification on its own, no matter how GoBD-compliant its documentation otherwise is. Anyone who actually wants to use this simplification needs a till system capable of generating e-invoices directly at the point of sale. The explanatory memorandum to the ordinance also only fixes part of the implementation details, leaving room for interpretation.

What applies to B2B cash sales regardless of the KassenSichV change

No special rules apply to cash-paid services. The general B2B e-invoicing obligation runs independently of the payment method and independently of the KassenSichV amendment: since January 1, 2025, every company must be able to receive e-invoices. A transition rule for sending invoices applies until the end of 2026, under which paper invoices or unstructured PDFs remain permissible with the recipient's consent. From January 1, 2027, companies with prior-year revenue above €800,000 must issue e-invoices (kassensichv.net); smaller businesses get a transition period until the end of 2027. From 2028, the obligation applies to all companies regardless of revenue.

The 2026 KassenSichV amendment therefore creates no new obligation. It only creates a technical option for cases where an e-invoice must or should be issued anyway — and even that option is tied to the till as the point of issuance.

The 250-euro threshold is not a new feature of the ordinance

One common misconception deserves correction: invoices up to €250 gross may still be issued as "other invoices" — a simple cash receipt generally suffices. This small-amount threshold derives from Section 33 UStDV in conjunction with Section 14(6) UStG and exists unchanged in VAT law, independent of the KassenSichV amendment. Above €250 gross, a business meal or a hardware-store purchase may still require an e-invoice if the issuer does not make use of the transition rules (NWB Experten-Blog). In such cases, it can make sense to issue an "other invoice" — such as a cash receipt — on the spot, which is later corrected by an e-invoice. Some business articles incorrectly present this €250 threshold as a new "hospitality special rule" introduced by the February 2026 ordinance; that claim is not substantiated.

What this means for receipt processing in practice

Businesses handling cash sales to corporate customers now need to technically distinguish three cases: the cash receipt up to €250, the combined receipt-invoice generated by the till itself under Section 6 sentence 2 no. 3 KassenSichV, and the separately issued e-invoice above the relevant thresholds. A documentation and bookkeeping system that manages receipts in a GoBD-compliant way from the original document through to booking needs to represent all these receipt types within a single data basis — including cases where a cash receipt is later corrected by an e-invoice and both documents must remain linked to the same business transaction. This interface between cash receipt and e-invoice is technically more demanding than the ordinance suggests at first glance, precisely because the point of issuance and the bookkeeping system are often not the same instance. Anyone wanting to check whether their own receipt chain already separates these cases cleanly should ask directly: is the e-invoice generated at the till or only afterward — and can that be proven within the receipt itself?

Fines for violations of KassenSichV or Section 146a AO can reach up to €25,000. In addition, the Fourth Bureaucracy Relief Act shortened the retention period for accounting documents from ten to eight years as of January 1, 2025 — which does not lower the requirements for a complete, auditable chain of receipts, only the period over which it must remain verifiable.