We are a distributor, not a supplier, of cash register systems – may we sell our old cash register solutions on storage per 1st of January 2017 before 1st of January 2019?

The new Cash Register System legislation does not prevent distributors selling these types of cash register systems. The enterprises with a bookkeeping obligation may use these systems until the 1st of January 2019. You have a disclosure requirement, and must inform the customer that they have until the 1st of January 2019 to upgrade the system or provide a new cash register system.

The field of action of the new Cash Register System Act, ref. section 1:

"This Act applies to suppliers of cash register systems as defined in Section 2, letter e. The Act defines requirements for cash register systems etc. offered for sale, lease or loan to enterprises with a bookkeeping obligation as referred to in the Bookkeeping Act, Section 2."

A supplier of a cash register system is defined in the Cash Register System Act section 2 letter e:

"supplier of cash register systems: manufacturer or importer which, either directly or through a distributor, offers cash register systems for sale, lease or loan to an enterprise with a bookkeeping obligation as referred to in Section 1, and distributors and others which adapt cash register systems to an individual enterprise with a bookkeeping obligation,"

Suppliers of a cash register system may only sell systems that meet the requirements in the Cash Register System Act and Regulations after the 1st of January 2017, either if the supplier sells their systems directly or through a distributor. A distributor that is neither a producer nor an importer, just a seller of the system without making any adjustments in the system for the customer, is not a supplier according to the Cash Register System Act.

The legislation does not prevent these distributors selling the cash register systems they have on storage per 1st of January 2017. The customer must be informed that the system must be upgraded or replaced by the 1st of January 2019.