Virtual online cash register - a compendium of knowledge


Poland is technologically catching up with other EU countries and joins those who allow the use of a cash register in the form of software. From June 1, 2020, this solution applies to a specific group of entrepreneurs, while in accordance with the announcements of the ministry, their catalog will be expanded in the future. The online virtual cash register is governed by two regulations. What is worth knowing about it? We answer in the article.

What was the purpose of an online virtual cash register?

For taxpayers, the introduction of an online cash register was not only an implementation problem, but also a financial problem. The government decided to introduce a new type of cash register precisely in order to reduce the costs related to the exchange for online devices for subsequent groups subject to the obligation of such exchange. It is assumed that an online virtual cash register is cheaper to maintain than a regular online cash register. Reduction of the shadow economy is also to be an added value. An online virtual cash register is considered to be an attractive solution for recording retail sales (i.e. to private individuals) and at the same time will strengthen the control element by providing real-time data on the trader's transactions (by linking to a central repository of cash registers).

The Ministry of Finance decided to implement the so-called an open model, i.e. an architecture implementation model based on public demand specifications, without limiting potential solutions, system and hardware platforms, programming languages, etc. The Ministry of Finance indicates that it will be possible to add new functions or services provided by independent entities to the virtual cash register.

Virtual online cash register - implementation

In the first stage of implementing the virtual cash register, it is intended for a group of taxpayers, including in the transport industry or the accommodation and catering industry, defined precisely in the regulations. These groups can use virtual cash registers to facilitate and improve the business environment. Like the "regular" online cash registers used before, these cash registers have the function of transmitting data to the ICT system operated by the head of KAS via the ICT network. As a result, it will be possible to continuously, automatically and directly transfer data from cash registers regarding tax events that took place during their use to KAS. The collected data is used for analysis and control purposes. The data transmission control system in sales documents, which are stored in cash registers, is one of the most important instruments in the fight against the so-called shadow economy and helps to strengthen fair competition between entrepreneurs.

Online virtual cash registers are to be an alternative to cash registers used so far by taxpayers - cash registers with paper or electronic recording of copies or online cash registers.

Virtual online cash register - who will benefit first?

As already mentioned, the first industries for which virtual online checkouts can be implemented are, inter alia, the transport industry and the accommodation and catering industry. Pursuant to § 1 of the Regulation of the Minister of Finance on groups of taxpayers or types of activities for which it is possible to use cash registers in the form of software, the online virtual cash register may be used in relation to the activities listed in the table below.

From June 1, 2020

Type of activity


passenger car transport services, including taxi (exception: occasional transport)


car rental services with a driver

removal services for households

passenger road transport services:

  • vehicles powered by human muscles or drawn by animals

  • scheduled, intercity, public

  • scheduled, urban and suburban

passenger rail transport services:

  • urban and suburban

  • intercity

passenger transport services, cable cars, cable cars and ski lifts

sea ​​and coastal passenger and ferry transport services

inland passenger water transport services:

  • ferry

  • excursion boats

  • the rest

air transport services:

  • regular domestic passenger

  • non-regular domestic passenger, except for sightseeing purposes

hotel and similar services relating to accommodation


tourist accommodation and short stay accommodation services


services provided by camping sites (including motorhomes) and campsites


other services related to accommodation


restaurant and other catering services


other catering services


beverage preparation and serving services


sale of coal, briquettes and similar solid fuels made of coal, lignite, coke and semi-coke intended for heating purposes


From July 1, 2020

sea ​​and coastal passenger cruise services

inland passenger water transport services by cruise liners

food preparation and delivery services (catering) for external recipients


What technical requirements must the online virtual cash register meet?

Technical issues are regulated by two regulations:

  1. The Ordinance of the Minister of Finance of May 26, 2020 on cash registers in the form of software and

  2. Regulation of the Minister of Digitization of 28 May 2020 on the mobile application for the settlement of fare for passenger transport.

They regulate a wide range of online virtual cash registers, including how to keep records with their use, how to start and end their use, special cases and how to document sales. Additionally, the technical requirements are specified in Annex 1 to the regulation.

To download:

Annex No. 1.pdf Description: Technical requirements for cash registers

The online virtual cash register should have a confirmation from the President of the Central Office of Measures that it meets the conditions specified in Art. 111 sec. 6a of the VAT Act. This confirmation is issued at the request of the manufacturer, which should include, inter alia, manufacturer's declaration that each cash register placed on the market will be functionally and programmatically identical to the model cash register subjected to testing, which has received the confirmation referred to in Art. 111 sec. 6b of the VAT Act, and performs the functions referred to in Art. 111 sec. 6a of the VAT Act, and technical requirements for cash registers.

Starting work on a virtual cash register

Before starting the records, the taxpayer is obliged to perform fiscalisation, ensuring a connection enabling data transfer between the cash register and the Central Repository of Cash registers. Fiscalization is performed only in the cash register operation mode, when the cash register database does not contain any data, except for a unique number.

Additional records

The taxpayer, similarly to other types of cash registers, in the event of errors or returns is obliged to keep separate records specified in the regulation on cash registers in the form of software. This is because the online virtual checkout does not record returns of goods and accepted complaints about goods and services. In the event of an obvious error in the records, the taxpayer shall correct it immediately by including in a separate record of errors:

  1. incorrectly recorded sales (gross sales value and the amount of tax due);

  2. a short description of the cause and circumstances of the mistake and by attaching a fiscal receipt confirming the sale where there was an obvious mistake.

Download a free template of a record of errors from the article: Record of obvious errors on the cash register - template with an overview.

Start a free 30-day trial period with no strings attached!

However, if there are returns and accepted complaints about goods and services, which result in the return of all or part of the receivables (payment) for the sale, this is recognized in a separate record of returns and complaints containing:

  1. date of sale;

  2. the name of the good or service allowing for their unambiguous identification and possibly a description of the good or service constituting the extension of this name;

  3. the date of returning the goods or making a complaint about the goods or services;

  4. value with tax (gross) of the returned goods or the gross value of the goods or services being the subject of the complaint and the amount of tax due - in the case of full refund of the sales receivable;

  5. the amount returned (gross) and the corresponding amount of tax due - in the case of a refund of part of the sales receivables;

  6. a document confirming the sale;

  7. a protocol for accepting the return of goods or a complaint about goods or services, signed by the seller and the buyer.

Download the free return record template from the article: Returns records for the cash register - template with overview.

Daily and monthly report

Taxpayers who record sales on a cash register are required to generate a daily and periodic fiscal report (also known as billing, monthly). The daily fiscal report is issued electronically after the end of the sale for a given day, not later than before the first sale on the following day. If more than one transaction is settled at the same time, all started transactions should be closed before issuing the daily fiscal report. At the user's request, the cash register should enable the generation of a daily report in a paper form.

A periodic (monthly) fiscal report or a combined periodic (monthly) fiscal report should be prepared in a paper version after the end of the sale for a given month, by the 25th day of the month following the month. In this case, it is not possible to generate this type of report electronically.

Paper or electronic receipt

An entrepreneur using a virtual cash register is obliged to issue and issue a fiscal receipt to the buyer, without his request, when making a sale, no later than upon accepting the payment, regardless of the form of payment (this does not apply, however, to cash registers placed in automatic sale devices).

The method of receiving all or part of the amount due (payment) before the sale

What should i do?

in cash

issue a receipt and issue it, without the buyer's request, upon receipt of payment

by post, bank or credit unions, respectively to the taxpayer's bank account or to the taxpayer's account at a credit and savings union of which he is a member

issue a receipt and issue it, without the buyer's request, immediately after it is credited to the taxpayer's account, but not later than at the end of the month in which it was credited to the taxpayer's account, and if the sale was made before the end of that month, no later than when it was made

The receipt may be issued in paper or electronic form (with the consent of the buyer, in a manner agreed with him). The taxpayer should provide a legible printout of the fiscal receipt in paper form, and in the case of a fiscal receipt in electronic form - its legible view, enabling the buyer to check the correctness of the sale. Moreover, before approving the fiscal receipt, in order to eliminate obvious mistakes in the records, the taxpayer is obliged to verify the correctness of the issued document.

A fiscal receipt in electronic form is an electronic document issued using an online cash register, having the content consistent with the fiscal receipt in paper form, which is sent to the buyer with his consent and in a manner agreed with him.

When it comes to technical issues regarding receipts, the online virtual cash register should provide records of sales, ending each time with the issuance of a fiscal receipt by:

  1. entering subsequent items of the fiscal receipt and simultaneous creation of an electronic form of a document line containing a given item stored in the database of the cash register, without the possibility of deleting this item and the possibility of printing it at the same time;

  2. approval of the fiscal receipt and its immediate printing (not applicable to the self-service cash register) or, in the case of technical possibilities, immediate sending of the fiscal receipt to the buyer in electronic form, as well as saving the fiscal receipt in the database of the cash register.

Currently, there are no cash registers on the market that would allow the issuing of receipts in electronic form, because the regulation regulating the technical conditions enabling the transfer of receipts in an online form is still at the legislative stage.

Employee and taxpayer statement

The taxpayer is obliged to familiarize the person who keeps the records with him, i.e. the employee, before the start of its keeping and regardless of the manner and form of entrusting this person with this task, with the principles of keeping records, including the principles of issuing and issuing a fiscal receipt and the consequences of non-compliance with them. Prior to the start of keeping records, the employee submits a declaration to the taxpayer that he has read the information on the principles of records. The form of the declaration is included in Annex 3 to the Regulation on cash registers.

Storage of fiscal documentation

Taxpayers are required to keep fiscal documents for the period required by the Accounting Act and the Tax Ordinance and to provide access to them in accordance with certain conditions. As in the case of other types of cash registers, taxpayers keeping sales registers through cash registers are therefore required to keep copies of fiscal documents for 5 years, counting from the end of the calendar year in which the tax period expires (this is the tax liability limitation period). This means that, for example, the documents used to complete the PIT tax declaration for 2015 should be kept until the end of 2020.