fiskaly SUBMIT DE

Introduction

fiskaly SUBMIT DE is a cloud-based service provided by fiskaly Germany GmbH that assists in the fulfillment of the obligation to submit declarations of available Point of Sale (POS) systems per establishment according to § 146a (4) of the German Tax Code (AO) and section “1.16. Mitteilungspflicht nach § 146a (4) AO” of the corresponding Application Decree (AEAO). The service allows for the input and management of relevant data, the generation and syntactic validation of submissions according to § 146a (4), and the transmission of submissions to the ELSTER portal via the ERiC/ELSTER services. fiskaly SUBMIT DE is accessed via a RESTful API and managed through the fiskaly Dashboard.

The service enables POS providers (CUSTOMER) to provide this service to their merchants (END CUSTOMER) and/or use the service themselves as END CUSTOMER if they are directly liable as taxpayers.

Service Description

fiskaly delivers fiskaly SUBMIT DE as a JSON-based RESTful SaaS solution. Key aspects include:

Input, management, and retrieval of END CUSTOMER data.
Input, retrieval, and deletion of POS data — both for POS integrated with fiskaly SIGN DE v2 and for “external” POS not using SIGN DE v2.
Generation, retrieval, deletion, and transmission of submission datasets per establishment.
Syntactic validation of submission data using internal rules and the ERiC library, including validation via ELSTER.
Transmission of submissions to the ELSTER portal using fiskaly’s own ELSTER certificate; submissions are allocated to the END CUSTOMER via the END CUSTOMER data included in the submission.
The END CUSTOMER can verify submitted datasets via the PDF returned by ELSTER upon successful transmission, or by logging into their ELSTER account.
For a CUSTOMER with existing SIGN DE v2 integrations, fiskaly automatically retrieves all TSS and POS data relevant to the submission from SIGN DE v2. For non-SIGN DE v2 integrations, the CUSTOMER and END CUSTOMER are solely responsible for providing all required data.

📘Note

The service does not include: semantic validation of data (except as provided by ELSTER, e.g., verification of taxpayer ID existence); automation that initiates a new submission process (e.g., tracing changes in data); or responsibility for errors originating from the ERiC/ELSTER infrastructure.

Functionalities

Customer authentication: Secure API-based authentication of CUSTOMER.
Data management: Endpoints for input, retrieval, and deletion of END CUSTOMER data such as taxpayer data, establishment data, and POS data.
Submission generation: Generation of submission datasets per establishment, with syntactic validation against internal rules and the ERiC/ELSTER schemata defined by the German tax authorities.
Submission transmission: Transmission of validated submissions to the ELSTER portal using fiskaly’s ELSTER certificate. The service retries requests to ELSTER in case of temporary errors and forwards all other ERiC/ELSTER error responses to the customer.
Submission evidence: Retrieval of evidence of all submissions in the form of XML or PDF files.
SIGN DE v2 integration: For SIGN DE v2-integrated POS, automatic mirroring of TSS instances and POS data; changes in SIGN DE v2 resources are automatically reflected. The END CUSTOMER only needs to provide the additional dataset per POS required for submission purposes.
Non-SIGN DE v2 ERS support: For non-SIGN DE integrations, all relevant data is provided by the CUSTOMER via dedicated “external” endpoints. Mixed establishments (both SIGN DE and external integrations) are supported.
END CUSTOMER consent workflow: Before triggering transmission, the CUSTOMER must download the preview PDF, present it to the END CUSTOMER, and obtain confirmation of correctness and consent for transmission. This must be repeated for every transmission.

System Requirements

A valid contractual relationship with fiskaly permitting use of the service and providing access to the fiskaly HUB for the creation of authentication credentials.
An internet connection.
Integration of every POS with a certified Technical Security System (TSS).
No other special software or hardware is required.
API documentation and integration guides are available at workspace.fiskaly.com; a Postman Quick-Start collection is also available.

Maintenance and Support

fiskaly is committed to maintaining and updating fiskaly SUBMIT DE to ensure its security, availability, and compliance with requirements issued by the German tax authorities. The service is versioned according to semantic versioning; breaking changes result in new major releases, and all customer-facing changes are documented in a public changelog. The service depends on the ERiC/ELSTER infrastructure maintained by the German tax authorities; ERiC/ELSTER versions are supported for a limited time (10–17 months) before deprecation. fiskaly undertakes to update the service to ensure continued compatibility. Maintenance activities may result in the temporary outage of the service. As far as possible, these activities shall be announced at least two (2) weeks in advance; emergency maintenance activities may deviate from this. Customers are encouraged to subscribe to the fiskaly status page (status.fiskaly.com). fiskaly provides assistance via the fiskaly support portal (support.fiskaly.com), including FAQs, how-to guides, and support via dev-support@fiskaly.com or the Web Widget from the Dashboard, Support Page, and Developer Page.

Testing

fiskaly provides a TEST environment for fiskaly SUBMIT DE. This is a fully functional end-to-end system that transmits data to the German tax authorities. Submissions in the TEST environment are marked as test data and are not relevant for tax audits. New versions of the service are available in the TEST environment before their LIVE release. fiskaly is not responsible if real data is provided in the TEST environment.

Service Limitations

The service does not provide semantic validation of the data; completeness and correctness are the sole responsibility of the END CUSTOMER.
The service does not include automation that initiates new submission processes (e.g., tracing changes in provided data). Generation and transmission of submissions must be triggered by the END CUSTOMER or CUSTOMER acting on their behalf in accordance with legal requirements.
The service depends on the ERiC/ELSTER infrastructure maintained by the German tax authorities. fiskaly does not take responsibility for delays, outages, or errors originating from ERiC/ELSTER. The CUSTOMER is responsible for analyzing such errors and adapting their system’s responses accordingly.
ERiC/ELSTER may introduce breaking changes resulting in deprecation of a major version. The CUSTOMER is responsible for staying up to date and integrating new major releases as soon as they are announced and available in the TEST environment.
Usage of the same ORGANIZATION of type UNIT (previously type MANAGED) for different END CUSTOMERS is explicitly advised against and will likely result in erroneous submissions; fiskaly disclaims any liability for such cases.
To facilitate smooth operation, fiskaly strongly recommends that integrations distribute usage over time and avoid batch requests of tens or hundreds of submissions simultaneously.

Customer Obligations

Must correctly integrate the service as documented, bearing in mind the distinctions between SIGN DE v2 and external POS integrations.
Must inform themselves of the legal requirements and be able to provide — or enable the END CUSTOMER to provide — the complete and correct dataset required for submissions.
Before triggering each transmission, the CUSTOMER must download the preview PDF, present it to the respective END CUSTOMER, and obtain their confirmation of (a) the correctness of the submission data and (b) consent for its transmission to the tax authorities. This consent must be relayed via the legal consent field in the API and must be repeated for every transmission.
Each CUSTOMER ORGANIZATION of type UNIT (previously type MANAGED) must be mapped to a single END CUSTOMER. Customers intending to use the service on behalf of multiple END CUSTOMERS must create individual organisations of type unit (previously type managed) for each END CUSTOMER.
For SIGN DE v2 integrations: the CUSTOMER is responsible for providing the additional data required per POS beyond what is automatically retrieved from SIGN DE v2. Management (creation/disabling) of SIGN DE v2 TSS instances and POS clients via SUBMIT DE is not possible.
For non-SIGN DE integrations: the CUSTOMER is solely responsible for the provision of all required data via the external endpoints.
Must instruct or facilitate the END CUSTOMER to store tax-relevant data as the law dictates, especially submission files as evidence of fulfillment of obligations, regardless of the availability of the same data in the fiskaly SUBMIT DE service.
Must inform fiskaly of problems encountered in using the service via the support channels provided.
Must distribute usage of the service over time and avoid batch requests to facilitate smooth operation for all customers.
Must secure access to their data through appropriate user management and up-to-date information security measures.

Version: v.1 | Last updated: 2026/03/24

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