Cash discipline: cash limits, change float, and accountable funds

Online cash registers and 54-FZ are responsible for the fiscalization of every transaction. But how much cash can be kept in the drawer, how to issue the morning change float, and what to do in case of discrepancies during cash collection—that is cash discipline: it operates in parallel with fiscal requirements, not instead of them.

1. Limit of 100,000 ₽ — only between legal entities and sole proprietors#

The restriction on cash payments under a single contract applies exclusively to transactions between legal entities and/or sole proprietors. For individual buyers (regular retail), there is no cash limit at all — selling goods for cash in any amount to an individual is completely legal.

2. Cash balance limit in the organization's cash register#

A separate rule governs how much cash is allowed to remain in the register at the end of the day. The organization sets the balance limit itself by executive order, using a formula based on its revenue/payout volume. Cash exceeding the limit must be deposited into the bank or accounted for otherwise, unless a different cash pickup procedure is in place.

Small businesses and sole proprietors have the right not to set a balance limit at all — an executive order (or decree for sole proprietors) waiving the limit is sufficient. This is a real benefit for small businesses if a formal limit would only create extra paperwork.

3. Morning Float and Evening Cash Withdrawal#

Cash float is an administrative, non-fiscal transaction: money that the cashier places in the cash drawer before the shift to provide change.

Neither operation generates a fiscal receipt — 54-FZ does not regulate them, but without them, the calculated and actual cash balances at shift closing will not match, even though there is no real discrepancy (see section 6).

4. Cash Receipt Orders, Cash Disbursement Orders, and the Cash Book#

• Legal entities maintain a cash book and issue cash receipt orders (PKO) and cash disbursement orders (RKO). In practice, instead of issuing a cash receipt order for every sale, a single consolidated cash receipt order is issued for daily revenue based on the Z-report.
• Sole proprietors are entitled not to maintain a cash book or issue cash receipt/disbursement orders — this is a separate exemption under the Bank of Russia directive on cash operations (No. 3210-U) and is not linked to having an online cash register.

Regardless of status, fiscal tracking (receipts, Z-reports, OFD) is mandatory for everyone using online cash registers — exemption from the cash book does not exempt you from issuing receipts.

5. Accountable Cash Disbursements from Revenue#

Issuing accountable cash advances directly from the drawer containing daily revenue is allowed — it is documented with a cash expense voucher (RKO for legal entities); this is standard cash handling discipline, not Federal Law No. 54-FZ. However, this complicates evening reconciliation if staff forget to record the disbursement with a "cash drop"/"payout" operation on the POS terminal itself. It is simpler and more transparent to disburse accountable funds from the bank account, especially in businesses with a high volume of retail receipts where reconciliation occurs daily.

6. Cash Discrepancy During Cash Collection: Algorithm#

1. Count the drawer together — the cashier and the person collecting the cash.
2. Run an X-report — the expected amount according to fiscal data at the current moment.
3. Check the paid-in/paid-out log for the shift — the most common cause of discrepancy is change float or an interim cash removal that wasn't accounted for during the manual count. After adding these operations, the discrepancy often disappears.
4. If the discrepancy remains:
   • Shortage — incident report, investigation, possible recovery from the responsible person. A shortage is never processed with a correction receipt — a correction records an unrecorded transaction, not a loss of money.
   • Surplus — if the cause is found (a forgotten unrecorded sale), a correction receipt is usually required; detailed instructions are in the article "Cash Surplus in the Register"; if the cause cannot be identified — it is recorded via an inventory statement without a correction receipt.

7. Cash from a Corporate Buyer#

If a representative of another organization/sole proprietor pays in cash, two rules apply at once: a limit of 100,000 ₽ per contract (Section 1) and a regular cash receipt — just like for any customer, as payment from a legal entity changes nothing regarding the obligation to issue it. At the representative's request, the organization's details (TIN, name) are added to the receipt — for example, for an expense report; for details, see the article “Combined Payment, Points, and Discounts”, which covers the same case with a corporate card.

8. Example#

Building materials store, sole proprietor, order waiving the cash balance limit is issued. In the morning, starting float is 3,000 ₽; daily revenue per Z-report is 84,500 ₽ (60,000 ₽ in cash); at lunch, 40,000 ₽ is withdrawn for a bank deposit.

Expected balance = 3,000 + 60,000 − 40,000 = 23,000 ₽. Cash drawer count — 23,000 ₽, no discrepancies. Cash book and cash receipt/disbursement vouchers are not issued — sole proprietors are entitled not to keep them.

9. How to do this in Cenaly#

• Cash-in and cash-out are separate operations in a cash shift: they are recorded with the amount, time, and employee, without affecting fiscal counters.
• When closing a shift, Cenaly automatically calculates the expected balance (sales minus refunds, plus cash-ins, minus cash-outs) and compares it with the amount entered by the cashier — any discrepancy is visible immediately, linked to the shift and cashier.
• Legal entity buyer details are added via a separate field on the checkout screen.
• Receipt history — POS → Receipts (receipts); physical cash registers — via Cenaly Hardware Bridge.

10. Frequently Asked Questions#

Does the 100,000 ₽ limit apply to a legal entity's total daily purchases or per contract? Per contract, not per calendar day; artificially splitting a single order into multiple "contracts" is treated during audits as circumventing the limit.

Can change float be omitted if the POS accepts only cashless payments? Yes, but as soon as you accept even a single cash payment, change is required — which means a starting balance recorded via a separate transaction.

Does a sole proprietor need to register their waiver of the cash balance limit with the tax authority? No, this is an internal administrative document kept on file in case of an audit.

Is it mandatory to issue accountable funds directly from the cash register rather than from the checking account? No, both methods are legal; issuing cash is faster, but complicates reconciliation if the transaction is not recorded as a "cash out" (Section 5).

Related articles: cash surplus in the cash drawer · error-free POS shift · split payment, points, and discounts · POS shift in Cenaly

This material is for reference purposes only and does not substitute for professional accounting advice. Primary sources: Central Bank of Russia Directive on the Procedure for Conducting Cash Operations (No. 3210-U), Central Bank of Russia Directives on Cash Settlement Limits Between Legal Entities, Federal Law No. 54-FZ "On the Use of Cash Registers".