Off-Site Sales and Second Locations: Register Address and Separate Subdivisions

Weekend fairs, a second location across the street, a food truck parked near an office today and on the waterfront tomorrow — in all these cases, the cash register isn't tied to an address as strictly as it seems, yet it isn't completely free from address requirements either. We break down what to specify during registration and on receipts when the payment location doesn't match the address on the sign.

1. Payment Location Address for Mobile Trade#

For trading without a fixed location (fair, festival, off-site session), when registering a cash register, the payment attribute "itinerant/mobile trade" is set, and the installation address is specified as the address of the company/sole proprietor — rather than the address of each specific fair or venue where the cash register will be on a particular day.

In this case, the actual payment location is recorded separately, directly on the receipt:

This is the same logic applied to delivery couriers — the registration address is not tied to a specific location, while the payment details are additionally specified at the receipt level (for details on the parallel setup "cash register outside the payment location", see the article "Receipts for Delivery").

2. One POS for two locations: moving it back and forth#

Formally, a POS register is registered with a link to a specific installation address — if it is a permanent location (and not mobile trade from §1), physically moving the same POS between two permanent addresses back and forth without taking this binding into account will not work. Options:

1. Re-registration upon every move — formally possible, but impractical in practice if locations change more frequently than once every few weeks: each change of address is a separate registration procedure.
2. "Mobile/itinerant trade" attribute — suitable if the activity is mobile by nature (fairs, temporary locations), rather than "two permanent stores saving money on a second POS".
3. A separate POS for each location — the most common choice for two permanent addresses: cheaper and simpler than setting up a mobile trade scheme or re-registering for every move, and it pays off by eliminating address discrepancy risks.

Bottom line: "one POS traveling between two permanent stores" is a scenario that the law does not describe as a convenient use case; for regular operation at two permanent addresses, standard practice leans toward option 3.

3. Separate Subdivision and Cash Register#

Under the Tax Code, a separate subdivision is established when an organization creates a permanent workplace for a period exceeding one month at an address different from the address of the organization itself — and the tax authority must be notified of this separately from the fiscal register issue.

How this relates to the cash register:

• A separate subdivision itself does not "have" a cash register as an independent entity of registration — the fiscal register is registered to the organization (legal entity), but with the installation address equal to the address of the location where the cash register is physically located, including the address of the separate subdivision;
• opening a second permanent location for a period of more than a month is a reason to check two different requirements simultaneously: notification of a separate subdivision (tax registration) and the correct installation address in the fiscal register registration (cash discipline) — these are different procedures, and completing one does not replace the other.

If the location is temporary (less than a month, a one-off fair), the status of a separate subdivision usually does not arise, and the rules for mobile trade from §1 apply.

4. Combining an Offline Location and Online Orders on a Single POS#

It is permissible: a single POS can handle both payments in the dining area/at the counter and orders placed via the website/app simultaneously — to do this, the online settlement flag is enabled in the settings alongside the standard mode, and the POS switches between them depending on the transaction type. Technically, this means that receipts for online orders are marked with the corresponding flag, while receipts for in-person sales are standard, without it; the POS software does this automatically based on the order source.

5. Food Truck: Place of Settlement "Vehicle"#

In practice, for mobile trade from a vehicle (food trucks, retail trailers), the receipt specifies a place of settlement such as "vehicle, license plate no. ..."—a variation of the same principle from §1: the installation address in the registration is the company's address, while the actual place of a specific settlement is specified for each individual mobile unit. Double-check the wording against what your POS FFD supports: some models allow entering custom text in the place of settlement field, while others are restricted to pre-set templates.

6. Markets and Fairs: Where the Exemption Remains#

The cash register exemption for trading at retail markets and fairs has been significantly narrowed in recent years, and it no longer automatically covers trade "from any stall." Following the general direction of these changes:

• some non-food goods are exempt only within a list approved by the government — this list is periodically revised, and items exempt yesterday may be removed today;
• some food goods sold from counters, mobile shops, and trailers at retail markets and fairs retain a broader exemption, but even here there are exceptions depending on the product type and outlet format.

The boundaries of this exemption are defined in detail by law (specifying the exact outlet format and product category). Before relying on an exemption for a specific retail location, check the current list and the wording of Article 2 of Federal Law No. 54-FZ, rather than relying on the general assumption that "no cash register is needed at a market": for a significant portion of today's market trade, this is no longer true.

7. "Settlement outside the installation site" attribute#

This attribute in the cash register registration data indicates that the physical device may be located somewhere other than where the settlement with the customer actually takes place (a classic example is remote fiscalization during delivery or vending). It affects which additional requisites can/must be specified on the receipt itself (for example, the actual address or another identifier of the settlement location) and how the tax authority matches the registration address with the actual sales geography during automated control. This is a separate setting from the "mobile/itinerant trade" attribute from §1 — they serve different purposes and in some workflows (for example, courier delivery) are used together.

8. Example#

A coffee shop with a permanent location in a shopping mall sets up a stand at a city weekend fair once a month. For the stand, a separate GPS-enabled smart terminal is used, registered with the "itinerant/mobile trade" flag and an installation address matching the legal address of the sole proprietor. At the fair, the POS terminal automatically inserts the actual coordinates of the location into the receipt. Meanwhile, the main POS terminal in the shopping mall continues to operate at its address without changes — both POS terminals are independent, and re-registration of the main location is not required.

9. How to do this in Cenaly#

• For mobile sales points, smart terminals and mobile POS devices connected via Cenaly Hardware Bridge support manual daily entry of the payment location — without the need to re-register the cash register for each site.
• Combining offline sales and orders from the QR menu/website on a single POS is configured at the location level — both streams are fiscalized by a single POS register with the correct payment attributes.
• Multiple outlets belonging to a single legal entity (including separate branches) are managed in Cenaly as individual locations with their own POS settings — making it easy to keep the installation address of each location in order.
• For more details on the mobile fiscalization model common to delivery and mobile sales, see the article "Receipts on delivery".

10. Frequently Asked Questions#

The fair lasts one day — is it mandatory to change the cash register registration for just one day of trading? If the cash register is already registered with the mobile/itinerant trade flag, nothing needs to be changed — the actual place of settlement for that day is simply entered in the outlet settings. Re-registration is required only if the cash register did not originally have this flag.

We keep the cash register at home and bring it to two different fair venues in turn — is this mobile trade, or do we need two cash registers? This is a classic case of mobile trade from Section 1: the installation address is the sole proprietor's/company's legal address, while the actual place of settlement at each venue is recorded separately in the receipt (via GPS or manually).

Our separate subdivision has been open for over a year, but for some reason the cash register was never re-registered to its address — is this a violation? Yes, if the cash register is physically located and operating at the separate subdivision's address, but a different address is specified in the registration data, this is a discrepancy similar to an address error during a regular relocation and should be corrected as soon as possible.

Can the "online payments" flag and the "mobile trade" flag be set on the same cash register at the same time? These are different flags for different operation scenarios of a specific cash register — check with your service center (CTO) or in the CCP user account to see which combinations of flags are supported by the registration form for your model and FFD (fiscal data format) version.

Related articles: receipts upon delivery · cloud cash register · POS in restaurant and cafe · cash register registration with FNS

This material is for informational purposes only and does not replace a consultation with an accountant or a CCP registration specialist. Primary sources: Federal Law No. 54-FZ "On the Use of CCP" (including Art. 2 on exemptions), FNS methodological guidelines (kkt-online.nalog.ru), Tax Code of the Russian Federation (separate subdivisions), Art. 14.5 of the Administrative Code of the Russian Federation.