3. Practical Implications for Payroll Processing
ServicesOutsourcingHR & PayrollPayroll Newsletter March 2026The New L16 Pay Slip
Practical Implications for Payroll Processing
Some elements of the L16 expansion are mainly an interface matter—primarily affecting payroll software providers (e.g., automated transfer of recorded fringe benefits to code 210 fields, separate disclosure under § 68 (1) and (2) EStG). However, other mandatory disclosures pose organisational challenges for payroll teams. This applies especially to tax exempt meal vouchers, described below.
Challenges with Meal Vouchers
The tax rules remain unchanged:
- Restaurant vouchers up to EUR 8.00 per working day,
- Grocery vouchers up to EUR 2.00 per working day (§ 3 (1) no. 17 lit. b EStG).
What is new is that tax‑exempt meal vouchers must be recorded in the payroll account (§ 2 Payroll Account Regulation) and in the L16 (under “Other deductions”).
- A dedicated payroll wage type is required (for information only, without payment effect). It is no longer permissible to process meal vouchers solely via accounting.
- A functional data flow between operations, accounting and payroll must ensure that payroll is informed of issuance and amounts.
- It is not yet definitively clarified whether monthly recording is required or annual bundled recording (e.g., in December) is acceptable. Since § 2 does not mandate ongoing entries, bundled recording seems defensible, but BMF confirmation is pending.
Meal Vouchers: Distinguishing Workplace Catering vs. Meal Subsidies
The new payroll‑recording requirement applies only to tax‑exempt meal vouchers (§ 3 (1) no. 17 lit. b EStG). It must be distinguished from:
- Tax‑exempt workplace catering (§ 3 (1) no. 17 lit. a EStG) such as a staff canteen → no payroll recording.
- Meal subsidies (cash allowances), which generally constitute taxable income (see Rz 93 LStR), unless all requirements for digital meal vouchers are met (Rz 95b LStR: personal identification, valid once daily, exact allocation, irrevocable entitlement).
The following table compares meal vouchers, workplace catering and cash meal subsidies in terms of tax treatment and payroll recording:
| Provision by the employer | Tax treatment | Recorded in payroll account and L16? |
| Free or subsidised workplace meals (e.g., canteen) | tax‑exempt | no |
| Restaurant vouchers up to EUR 8/day; grocery vouchers up to EUR 2/day | tax‑exempt | yes |
| Digital vouchers up to EUR 8/2/day (if requirements met) | tax‑exempt | yes |
| Amounts exceeding the tax‑exempt limit | taxable | yes (as taxable remuneration) |
| Advance cash payments for meals | taxable | yes |
| Cash reimbursements without vouchers | taxable | yes |