The BMF (German Federal Ministry of Finance) has issued an announcement letter on the non-objection regulation for the use of electronic recording systems within the sense of § 146a AO without a certified technical safety device upon 31.12.2019. Essential contents of the BMF letter are:
- The technically necessary adaptations and upgrades must be carried out immediately and the legal requirements must be fulfilled immediately.
- In order to implement the upgrade of electronic recording systems (electronic or computer-aided cash register systems or cash registers with cash register function), there is no objection if these electronic recording systems do not yet have a certified technical security device until 30 September 2020 at the latest.
- Notification pursuant to § 146a para. 4 AO (notification of electronic recording systems of cash registers acquired before 1.1.2020) shall be waived until the use of an electronic means of transmission is available.