The Risks of Running a POS Machine Without Registering It with the Revenue Department

VAT-registered restaurants that use a POS machine to issue tax invoices must first get approval from the Revenue Department. Using one without registering it can be a legal offence and undermine the reliability of your accounting records.

These days many restaurants use a POS machine to manage orders and take payments at the counter, because it speeds up service and cuts down on errors from calculating bills by hand. But for restaurants registered for value added tax (VAT), using a POS machine to issue tax invoices isn't just a matter of convenience — there are legal requirements owners need to know and follow.

Why VAT-Registered Restaurants Must Register Their POS Machine

Under Section 86/6 of the Revenue Code, businesses that use a cash register machine (including a POS system) to issue abbreviated tax invoices must apply for approval from the Revenue Department before putting it into actual use. This means filing Form PP 06 (ภ.พ.06) along with supporting documents such as the machine's specifications, brand, model, and serial number for the equipment actually used in the restaurant.

In plain terms, every POS machine used to issue receipts or tax invoices to customers must first be "registered" with the Revenue Department — you can't just buy one, install it, and switch it on.

The Risks of Using a POS Machine Without Registering It

Many restaurants skip this step, assuming a POS machine is just a sales tool with nothing to do with tax. In practice, though, if a VAT-registered restaurant uses a POS machine to issue tax invoices without approval, it can lead to the following consequences:

  • The tax invoices issued may not be legally valid, since the machine was never certified by the Revenue Department — this can affect the customer's right to use the invoice to claim an input tax credit.
  • Risk of an audit — if officials find that a restaurant is using an unregistered cash register machine, it may be called in for an explanation or face legal action.
  • Fines and imprisonment — using a cash register machine to issue tax invoices without approval from the Director-General of the Revenue Department is an offence under Section 90/3(2) of the Revenue Code, punishable by up to 6 months' imprisonment, a fine of up to 10,000 baht, or both.

Steps and Timeline for Getting POS Approval

Business owners who want to use a POS machine to issue tax invoices should prepare the following documents and take these steps:

  1. Complete the application form for approval to use a cash register machine, PP 06 (ภ.พ.06), separately for each place of business.
  2. Attach the machine's specifications, brand, model, and serial number.
  3. Attach the notification form for preparing and storing electronic documentary evidence, PO 11 (ภ.อ.11), along with a flowchart of the POS system used.
  4. Attach a floor plan showing where the cash register machine is positioned in the restaurant, plus a diagram of how it connects to any computer equipment (if applicable).
  5. Submit all documents to the Area Revenue Office where the business is located, or file online through the channel designated by the Revenue Department.

Processing generally takes around 30-45 business days from the date the application is filed, so documents should be prepared and submitted at least 45 days before the machine is meant to go live. Importantly, while approval is pending, the POS machine should not be used to issue tax invoices, because the document numbers it generates run in a continuous sequence — issuing documents before approval is granted is also treated as an offence under the law.

Summary

Using a POS machine does make front-of-house operations in a restaurant faster and more convenient. But for VAT-registered restaurants, the registration step with the Revenue Department is not something to skip — the law is clear on this, and the penalties for non-compliance include both imprisonment and fines. If you're not sure what your restaurant needs to do, it's worth consulting an accounting and tax professional before you install your POS system, so you can plan the timeline properly and avoid problems down the road.