Can you use a terminal without a cash register?

Customers are used to paying by card anywhere — in a store, café, or even at the market. To make this possible, businesses install payment terminals. But can you use them without a cash register? It’s not that simple: it involves legislation, tax reporting, and business risks.

At the same time, a question arises that concerns many: is it possible to work with a terminal without a cash register, and is it necessary to combine them?

How terminals and cash registers work

To understand the requirements of the law, it is first necessary to distinguish between the functions of the two devices:

• A payment terminal accepts card payments, reads data, performs authorization, and debits funds from the customer’s account.
• A regular or software cash register (cash register) fiscalizes the sale, i.e., creates a fiscal receipt that displays information about the transaction.

The terminal does not generate a fiscal receipt; it only conducts the transaction. Therefore, without a connection to a cash register, the transaction is legally considered incomplete.

Can a terminal be used without a cash register?

No, it cannot. If an entrepreneur accepts payment via a payment terminal, they must use a cash register or software cash register. This is because a payment transaction made via a payment terminal requires fiscalization.

Mandatory use of cash registers/payment terminals

There are certain exceptions when cash registers/payment terminals are not mandatory, for example, for sole proprietors in the first group of the single tax who:

• trade exclusively in villages,
• do not exceed income limits,
• do not trade remotely,
• do not sell excisable goods.

However, if such entrepreneurs use a payment terminal, they are also required to use RRO/PRRO.

Is it mandatory to connect a cash register to a payment terminal from March 1, 2025?

No, there is no such obligation. Current legislation does not require connecting or combining a cash register (CR or PR) with a POS terminal.

The changes made by Order of the Ministry of Finance No. 601 of November 22, 2024, to Regulation No. 13 also did not introduce such a rule.

On the contrary, the updated rules allow for a clear distinction between the concepts of which terminal is considered “connected” to the RRO and which is considered “combined.” This is important because previously, vague wording led to many disputes during inspections.

The legislation introduced two important terms related to payment terminals:

• A connected terminal is a separate device or program that interacts with each other through data exchange.
• A combined terminal is a single device or program that performs both functions simultaneously.

In addition, paragraph 4 of Section II of Regulation No. 13 stipulates that fiscal and expenditure receipts (lines 12–17) must contain information about payments made using a payment card through a terminal that is connected or combined with a cash register/payment terminal.

The tax service also confirms that the law does not establish a requirement to connect cash registers/payment terminals to POS terminals.

Can a terminal be used without a cash register in a simplified system for sole proprietors?

This question most often arises for sole proprietors on a single tax. Indeed, the law allows certain categories of sole proprietors to operate without a cash register under certain conditions (for example, a small amount of income or specific types of activities). But if an entrepreneur installs a terminal, card payments are still treated as settlement transactions.

Therefore, even sole proprietors under the simplified taxation system must use a cash register or cash register software when accepting card payments.

What is the difference between working with cash and cards?

At first glance, it seems that cash is more difficult to control, and non-cash transactions are already visible at the bank. But the law makes no distinction: both cash and card payments are settlement transactions that must go through a cash register. The bank only transfers funds, but does not perform fiscalization.

Liability for violations

Businesses face fines not only when a fiscal receipt is completely missing. Any deviation from the established rules for conducting settlement transactions is considered a violation. The tax authorities check not only the fact of issuing a receipt, but also its correctness and authenticity.

The most common situations that may result in penalties are:

• payment without a registered cash register or payment terminal, regardless of whether it is cash or card;
• errors in the amount indicated on the receipt;
• absence or inaccuracy of mandatory details (date, time, fiscal number, name of the product, etc.);
• failure to issue a receipt to the buyer, both in printed and electronic form.

The first violation may result in a fine of 100% of the transaction amount, and a repeat violation may result in a fine of 150% or more. This makes experiments with “savings” on cash registers unprofitable.

Using a payment terminal without a cash register is not a “loophole” in the law, but a violation that can result in significant fines for the business. The terminal and the cash register perform different functions: one conducts the transaction, the other fiscalizes the payment. Therefore, they do not replace each other, but complement each other.