One Till, Three Rulebooks
EU baseline vs. Germany’s KassenSichV vs. France’s NF 525 & “no-ticket” law (mid-2025 edit)
My empirical observations: Receipts (Quittungen) vary in length, duplicates, and information printed on it. There seems to be a relationship (=correlation) between restaurant size and information printed: the smaller the shop the longer the receipt. Thus, positive correlation.
Here my theory on these observations to make causal inference.
EU VAT Directive – the minimum everyone must meet
Scope: Only says what information an invoice has to carry so VAT can be recovered in any Member State.
Key facts:
Two formats allowed: full invoice and simplified invoice (for sales up to about €400). vatupdate.comeur-lex.europa.eu
Mandatory fields are basic: issue-date, sequential number, seller and buyer IDs, brief description, taxable amount, VAT rate and VAT due. vatupdate.com
What’s missing on purpose: No mention of cryptographic signatures, hardware security modules or how cash registers should store data. Each country is free to fight fraud its own way.
Germany – KassenSichV (since 1 Jan 2020)
Why it exists: Billions lost to “zapper” software that erased cash sales after hours.
Core requirements:
Every POS must be anchored to a TSE security module that time-stamps and cryptographically hashes each transaction. haufe.de
Receipt duty (“Bonpflicht”): a receipt must be offered for every sale, paper or digital. bundesfinanzministerium.de
From 1 Jan 2024 the slip must also show the serial numbers of both the till and the TSE, plus the rolling signature counter. bundesfinanzministerium.dehaufe.de
Data export must follow the uniform DSFinV-K CSV/JSON schema so auditors can read it instantly. kassensichv.net
Penalties: up to €25 000 for a non-compliant register or missing receipt. kassandro.de
Everyday effect: Small cafés often print a long, code-heavy ticket; big chains hide the hashes in a compact QR. The flood of thermal paper has provoked calls to roll the rule back. zeit.de
France – NF 525 software & the paper-saving ticket law
Why it exists: Same sales-suppression threat, tackled two years earlier.
Core requirements:
A cash register must run NF 525-certified software proving its data can’t be altered (inalterability, security, conservation, archiving). bofip.impots.gouv.fr
2025 upgrade: self-attestation is disappearing; only a third-party certificate from an accredited lab is accepted after 1 Sept 2025. entreprendre.service-public.fr
Receipt rule: Since 1 Aug 2023 shops may not auto-print a ticket. They must still provide one (paper or digital) on request or for a few legal exceptions. entreprendre.service-public.fr
Penalties: €7 500 per uncertified cash register, repeatable after 60 days if still non-compliant. entreprendre.service-public.fr
Everyday effect: Most shoppers leave with no slip at all; the few who ask get a normal-looking ticket—no crypto block needed.
How the two national systems really differ
Germany straps every sale into a tamper-proof hardware safe and insists the customer gets a stamped copy by default. France relies on software audits plus a “print-only-if-you-want” rule to save paper. Both approaches satisfy the EU invoice checklist, but they diverge sharply on technology, user experience and environmental optics.
Practical tips for merchants, developers and consultants
EU compliance is only step one: meeting Article 226 fields will not satisfy the German or French taxman on its own.
Budget country-by-country: German roll-outs must buy or rent TSE modules; French roll-outs must budget for NF 525 certification and its renewals.
Design the checkout flow accordingly:
Germany: hide the long hash in a QR, and offer e-bon by e-mail or wallet.
France: default to an on-screen prompt—“Need your receipt?”—with instant e-receipt delivery.
Keep an eye on Brussels: The EU’s “VAT in the Digital Age” package, politically agreed in late 2024, will introduce cross-border real-time e-reporting later this decade. Plan new POS projects with that horizon in mind. europarl.europa.eutaxation-customs.ec.europa.euconsilium.europa.eu
Bottom line: The EU provides the invoice passport photo; Germany bolts that photo into a cryptographic safe and hands every customer a copy, while France trusts a certified camera and only prints the photo if you ask. Different tools, same goal: shrink the VAT gap without shrinking public trust.