Law and deadlines

TSE-Pflicht

In one sentence

TSE-Pflicht is the requirement that an electronic till carries a certified technical security module which signs every transaction as it is recorded, so that entries cannot be changed or removed afterwards without the change being apparent.

TSE stands for technische Sicherheitseinrichtung, a certified security module attached to an electronic till. Its job is narrow, because every transaction the till records is signed at the moment it is recorded, with a sequential number, a time stamp and a checksum. An entry therefore cannot be deleted or edited afterwards without the gap or the change becoming visible in the log.

The obligation comes from the Kassensicherungsverordnung and attaches to the electronic recording system rather than to a line of business. That distinction matters, because pharmacies sometimes assume the requirement belongs to retail and ends at the medicine counter. If a service is rung up on the same till as a box of tablets, the same signing requirement covers it. If the service is taken on a second device, whether a tablet in the consultation room or a card terminal with its own app, that device is part of the recording system too.

Three practical questions follow from that:

  1. Does the existing till already hold a working module, and can the pharmacy demonstrate that rather than infer it from the age of the system?
  2. Has the till been reported to the tax office as the rules require?
  3. Is a receipt issued for every single transaction, given that a self-pay service is the situation in which a receipt is most easily forgotten?

Modules do not last indefinitely, because the certificate inside a TSE has a limited life and the module has to be renewed or exchanged before it runs out. Once it has expired the till is no longer compliant even though it carries on working normally, which is the awkward part, since nothing visibly breaks. Providers usually give warning of the date, but the responsibility stays with the pharmacy, so the expiry belongs in the same calendar as device calibration rather than in an email folder.

Signing is the technical half of GoBD-konforme Kassenführung, while completeness, order and retention of the records are the other half. Where the money comes from the customer instead of an insurer, the till record becomes the primary evidence for Privatliquidation and for ordinary Rechnungsstellung an Selbstzahler. A service in the apothekenübliche Dienstleistung category is usually paid in precisely that way.

Whether one specific configuration of till, terminal and booking tool satisfies the requirement is a question for the till provider and the Steuerberater before the first paid appointment rather than after it.

This glossary entry is general information about German pharmacy law and practice. It is not legal advice. For binding guidance on your own pharmacy, contact your Landesapothekerkammer.

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