Whether a business must use Electronic Fiscal Software is not decided only by its legal form or size. Administrative Instruction (MF) No. 01/2026 connects the obligation to the type of supply: retail sales to final consumers, services in premises open to the public and similar activities are recorded through SEF. Business-only supplies follow the tax-invoice rules.
The basic rule for final-consumer sales
A taxpayer supplying goods or services to a final consumer issues a fiscal receipt regardless of whether payment is cash, card or another method. The rule covers retail, public-facing service locations and similar activities.
Public institutions that accept cash for services are also among the categories specified for SEF use.
When supplies are only business to business
A business supplying goods or services only to persons engaged in economic activity uses a tax invoice under the applicable legislation. This is not a blanket exemption for every company with business customers; the actual nature of each supply matters.
Businesses with both B2C and B2B sales
Where one entity sells to consumers and businesses, the workflows should be explicit. Non-exempt consumer transactions are recorded individually in SEF, while B2B documents follow tax-invoice requirements.
- Identify the customer type before completion.
- Choose the receipt or invoice workflow before closing the sale.
- Do not replace a required receipt with an internal document.
- Seek professional advice for borderline cases.
Document the decision
Map every channel—counter, delivery, online sale, B2B contract and institutional payment. Record the customer type, payment method and document for each, then verify the map with your accountant and current ATK guidance before configuring the POS.
Final consumer is not determined only by the buyer label
The Instruction primarily defines a final consumer as a non-business individual, but also covers cases where a business person, legal person or institution uses a purchase for its own needs rather than resale or development of its activity. The label “B2B” alone therefore does not decide the document.
Supplies to persons engaged in economic activity use a tax invoice except where the supply falls within the final-consumer definition. Classify the actual transaction.
Free supplies and prepayments also have rules
A free supply to a final consumer requires a receipt for tax purposes, and a receipt is also required for a payment made before supply.
Where payment is contractually deferred, the issue time is the supply. These scenarios should be configured and tested rather than handled with improvised documents.
Turn the requirement into an operating procedure
Technical requirements need to become steps that staff can follow: who opens the shift, how connectivity is checked, when a sale is complete and who handles an unclear receipt status. Keep the procedure short, written and tested on the real device.
Define escalation as well. An operator should never improvise through deletion or duplicate entry; they should know when to stop and contact a supervisor or support.
What to request in a SEF demonstration
Do not watch only one successful sale. Ask to see communication status, receipt history, offline work, retry, correction and operator trace. Those scenarios show whether the solution is designed for a real working day.
- A clear status for each receipt.
- A distinction between local errors and an ATK response.
- History without silent deletion.
- A defined maintenance and support process.
Pre-launch check
Use this guide as a basis for discussion with your team and software provider. The actual setup depends on your activity, locations and internal procedures.
- Define items, tax rates, prices and payment methods.
- Set operator roles and shift responsibilities.
- Test sales, corrections, offline work and reports.
- Document the workflow and train staff before activation.
Practical questions
Is a bank-only business automatically exempt? +
Not simply because of payment method. Final-consumer supplies require a receipt regardless of payment method; the supply, buyer and any specific exemption must be assessed.
What about a business with both B2C and B2B sales? +
Transactions requiring receipts are recorded individually in SEF, while supplies requiring invoices use the tax-invoice workflow.
Is generating a receipt enough? +
No. The workflow also needs identification, reporting, status, storage, corrections and an action trail under the applicable requirements and procedures.
Where should current SEF information be checked? +
Use official Tax Administration of Kosovo notices, guidance and channels because requirements and procedures may be updated.
How can I verify that a SEF is certified? +
Use the current register in ATK’s official portal and match the company, SEF name, unique number, version and platform to the proposed installation.
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