Legal Obligations When Buying Taxi Software: TSE, ELSTER, Order Log, DTA

In this chapter: the TSE on the taximeter · filing with the tax office · DSFinV-TW · the order log for hire cars · patient transport · receipt, card, working time.

The costliest mistake

Assuming “the software” takes care of the obligations by itself. The most important ones attach to individual devices and procedures — to the taximeter, to the Wegstreckenzähler (sealed odometer), to the reporting channel to the tax office. A dispatch program covers one and doesn’t touch the other; anyone who fails to check device by device ends up with gaps that only the tax audit reveals.

Taxi software is not a single thing but a bundle — dispatch, billing, driver app, often a taximeter connection — and the obligations are spread unevenly across it: some sit in the measuring device, some in the reporting channel to the authorities, some in the paperwork for the licensing authority. This chapter goes through them one by one.

Chapter 1 — The TSE on the taximeter

The Technische Sicherheitseinrichtung (TSE — technical security unit) is a certified signature module: every trip, every till transaction is recorded in it in a way that prevents unnoticed changes after the fact. The legal basis is § 146a AO (German Fiscal Code) in conjunction with the Kassensicherungsverordnung (KassenSichV — Germany’s cash register anti-tampering ordinance); since January 1, 2026, the taximeter must record via such a TSE. Where it is missing, the fine framework of § 379 AO of up to €25,000 applies — and, usually more unpleasant, the tax office’s right to estimate.

What matters is where the obligation sits: on the taximeter, not in the office software. Systems with a taximeter connection offer a TSE route; pure billing or dispatch programs do not — no defect, but the correct division of labour.

Two designs are permitted. A hardware TSE sits inside the device; a cloud TSE signs the taximeter data via an external connection. HALE offers the MCT-07-GBT taximeter with the TSE in the device and retrofits older models via the SEI-03-MBT signing unit; the WSZ-07 Wegstreckenzähler signs by itself, according to the manufacturer (as of 07/2026). MPC/TARIS, Seibt & Straub and fms/Austrosoft rely on cloud TSE — fms advertises “full BSI TSE certification” (BSI: the German Federal Office for Information Security), and Seibt & Straub has allowed self-activation by the operator since January 21, 2026. Taxi.de (Talex) reaches the TSE via its connection to HALE taximeters.

Remember

A TSE is certified by law — otherwise it would not be a TSE. The certification sits in the built-in component (such as a swissbit card). Not every provider publishes the BSI certificate number; MPC/TARIS and Seibt & Straub do not. That is no defect — but if you want to be sure, have the certificate ID written into the offer.

Two points tend to get lost in the sales conversation: after the TSE installation, a new calibration (Eichung) may become necessary — that is decided by the calibration authority, not the salesperson. And the TSE cards carry a BSI-limited validity and must be replaced when it expires, which means recurring costs. Older INSIKA taximeters (INSIKA: the predecessor security system for German taximeters) can be retrofitted or must be replaced, depending on the model.

One more warning: pure software “GPS taximeters” do not count in Germany as calibrated taximeters within the meaning of the Mess- und Eichgesetz (MessEG — the German Weights and Measures Act) and do not replace the calibrated device for a licensed taxi — a route taken, for instance, by the internationally oriented TaxiAdmin (as of 07/2026).

Chapter 2 — Filing with the tax office via ELSTER

§ 146a AO requires not only the TSE but also notifying the tax office which recording systems you operate — electronically via the “Mein ELSTER” portal (the German tax administration’s online portal).

Two of the systems reviewed document their own support for this: HALE with a “connection to Mein ELSTER for the cash register filing” in its data centre packages, Seibt & Straub with an ELSTER file for upload in its operator portal (as of 07/2026). The remaining providers make no public statements on this — which changes nothing about the obligation: you must file either way, yourself or through your tax advisor. Your tax office confirms the exact filing deadline.

Chapter 3 — The DSFinV-TW audit export

DSFinV-TW stands for Digitale Schnittstelle der Finanzverwaltung für EU-Taxameter und Wegstreckenzähler — the German tax administration’s digital interface for EU taximeters and odometers: the standardised format in which your taximeter data is output so that an auditor can read it in. It is needed in the unannounced cash register inspection under § 146b AO and in the tax audit with direct data access; the tax administration spelled out its application to the taxi trade in the application decree to the AO (German Federal Ministry of Finance, version of March 11, 2024).

A documented DSFinV-TW export is shown by HALE, MPC/TARIS, Seibt & Straub and fms/Austrosoft; Taxi.de delivers it via the HALE coupling (as of 07/2026). HALE additionally states ten-year audit-proof archiving in an ISO-27001-certified data centre in Germany; so does fms. For the buyer this means: this capability belongs on the device side of the offer — promised as a named export function, not as a marketing line.

Remember

TSE, ELSTER filing and DSFinV-TW export are three separate obligations on the same device. A system can fulfil one and stay silent on another. Ask about all three individually.

Chapter 4 — The order log for hire cars (§ 49 (4) PBefG)

A word of clarification: Mietwagen here means the licensed chauffeur-driven hire car under the PBefG (German Passenger Transport Act) — the vehicle with driver that Uber or Bolt partners operate — not a rental car from a car rental company. For it, § 49 (4) PBefG requires two things: the obligation to return to the business seat after every trip, and an order log (Auftragsbuch) recording the receipt of every transport order at the business seat.

Here lies one of the industry’s most expensive traps. The trip lists from Uber, Bolt or FreeNow are billing lists — not an order log within the meaning of the law. Relying on them risks, in an inspection, anything from a formal warning up to endangering the operating licence.

And here is the honest state of the software: none of the thirteen systems reviewed explicitly advertises an “order log under § 49 (4) PBefG”. Closest comes Fahrdienst Software with an “Auftragseingangsbuch” (order receipt log) that captures acceptance time, acceptance channel, orderer, pick-up point and destination, detects incomplete entries and exports as PDF or CSV — but the provider does not mention § 49 PBefG and points out expressly that proper use is the operator’s responsibility. TAXIKOMM24 logs orders and telephone connections chronologically with export, likewise without § 49 as a commitment. All remaining systems make no public statements on this (as of 07/2026).

Remember

No software takes the responsibility for a legally sound order log off your shoulders. Check whether a system captures the mandatory details of § 49 (4) PBefG and exports them without gaps — and don’t let anyone fob you off with a platform export.

Chapter 5 — Patient transport and the DTA procedure (§ 302 SGB V)

Anyone driving patients on behalf of Germany’s statutory health insurers bills via the Datenträgeraustausch (DTA — data media exchange) under § 302 SGB V (Book V of the German Social Code) — an electronic procedure using a certified transmission component. Handling it poorly risks deductions; MPC/TARIS warns in its own documentation of invoice deductions of up to 5% for missing DTA billing.

Whether a provider truly masters this can be checked objectively: the statutory health insurers keep an official register of approved software providers. In the excerpt for patient transport services retrieved on July 11, 2026, the systems reviewed that appear include DMRZ, MPC/TARIS (entry 107), Seibt & Straub (optiKASAB, entry 192) and TaxAb.

Other systems advertise DTA capability but were not found in this excerpt — among them SuE/TaMi, TAXI-Experte and Taxi.de. That is no verdict on their performance: a register excerpt is a snapshot, and a manufacturer may be listed under a different name or via a partner component. HALE and fms/Austrosoft capture patient transport data but document no DTA billing of their own; Fahrdienst Software only prepares the billing. If patient trips matter to you, demand proof of the official listing and clarify whether an add-on component such as dakota.le is required.

Chapter 6 — The smaller obligations: receipt, card, working time

Three further points belong on the list before signing. The receipt issuance obligation (Belegausgabepflicht): a receipt must be producible in the taxi as well; TSE-capable systems print it with a QR code. Card payment: not mandated everywhere in Germany, but affirmed for Berlin by the Higher Administrative Court — so mandatory depending on the city, and a card terminal coupled to the taximeter becomes a criterion. And working time documentation under the Mindestlohngesetz (MiLoG — the German Minimum Wage Act): it must record driver hours cleanly without harassing the drivers. The Berlin-Brandenburg Higher Labour Court ruled in 2018 that a driver does not have to press a standby button every three minutes; waiting times at the rank can be working time subject to pay. Several systems offer modules for this — Seibt & Straub with automatic break detection, SuE/TaMi with explicit recording of standby time (as of 07/2026).

Checklist for the sales conversation

• Does the taximeter have a certified TSE, and is the BSI certificate ID stated in the offer?
• Does the system support reporting the devices via “Mein ELSTER” under § 146a AO — or who takes care of it?
• Is the DSFinV-TW export explicitly promised, and for how long is the data archived audit-proof?
• For hire cars: does the system capture and export the mandatory details of the order log under § 49 (4) PBefG?
• Does the system bill patient trips via the DTA procedure under § 302 SGB V, and is the manufacturer officially listed as a software provider?
• Are receipt issuance, card payment and court-proof working time records covered?

---

Continue in the handbook: Cost traps · Contract clauses · back to the overview.

Last updated: July 11, 2026. This chapter explains rules with statute and source and is no substitute for legal or tax advice; for your individual case, the tax advisor, lawyer and the competent authority are the right address. Product information comes from the public manufacturer documentation of the systems reviewed.