Meal vouchers in Europe Meal benefit card rules in Germany in 2026
Meal benefit card rules in Germany in 2026
Germany has no meal voucher register and no accredited issuers. Instead it has two separate tax rules that a card can carry. The meal subsidy lets an employer fund up to 7.67 EUR per working day per employee in 2026. The benefit in kind allowance lets an employer load 50 EUR a month onto a restricted card for anything else. They rest on different legal bases and can be used together.
How much can an employer subsidise a meal in 2026?
Two numbers add up.
The Sachbezugswert, the official notional value of a working day meal, rises to 4.57 EUR per day in 2026. On top of that sits a tax free subsidy of 3.10 EUR, which is unchanged.
Together that is 7.67 EUR per meal. Across a month counted at 15 working days, the maximum meal subsidy comes to 115.05 EUR.
The two parts are treated differently. The 3.10 EUR is fully tax free. The Sachbezugswert portion is subject to a flat 25 percent tax, which the employer usually carries.
What is the 50 euro monthly allowance, and is it the same thing?
No, and conflating the two is the most common mistake in German benefit design.
The benefit in kind allowance lets an employer give an employee up to 50 EUR per month free of tax and social contributions, and vouchers and prepaid cards explicitly count. It is a monthly threshold rather than an allowance: exceed it by any amount and the entire sum becomes taxable, not just the excess.
The meal subsidy and the 50 EUR threshold run on separate legal bases. An employer can use both for the same employee in the same month.
Why this shapes the card. A card carrying the 50 EUR benefit in kind allowance has to be restricted, because an instrument that can be spent on anything is treated as cash and taxed as cash. A card carrying the meal subsidy has to be restricted to food specifically, and has to be able to count working days rather than calendar days. Programmes commonly run both purposes and have to keep them apart.
Does Germany restrict who may issue?
No. There is no register of authorised issuers as there is in Italy or France, and no national accreditation body for accepting merchants.
The consequence is that German benefit cards are ordinary payment cards on international networks, restricted by merchant category, issued through whichever licensed institution the provider has contracted. The compliance burden sits on demonstrating the restriction to the tax authority, not on holding a licence to issue vouchers.
That makes Germany the most straightforward European market to enter technically, and the least protected competitively.
What does the restriction have to achieve?
Enough that the card cannot function as cash. In practice that means blocking cash withdrawal outright, limiting acceptance to the merchant categories that carry the benefit, and being able to evidence both.
The requirements for treating a card as a benefit in kind rather than a cash payment were tightened, so a card designed before those changes may no longer qualify. Anyone reviewing an inherited programme should confirm the current position with a tax adviser rather than assuming the original design still holds.
What this means if you run a German benefit card
Three practical consequences follow from having no register and no accreditation body.
First, the merchant side is not your problem. There is no affiliated network to sign, no clearing body to join, and an ordinary payment terminal accepts the card. Compare that with Italy, where the law requires a contract with every accepting merchant.
Second, your differentiation is the product, not the licence. In markets with registers, being on the register is a barrier that protects incumbents. In Germany that barrier does not exist, so competition happens on app quality, employer tooling and price.
Third, your dependency is the issuing partner. A German benefit card provider does not hold the licence itself, so the licensed institution behind the card is a single point of failure. This market has already learned that lesson: providers here have had to migrate issuers when their partner failed, which is disruptive precisely because there is no national scheme to fall back on.
Germany compared with its neighbours
| Germany | France | Italy | |
|---|---|---|---|
| Register of issuers | None | CNTR accreditation | Ministry register |
| Merchant accreditation | None | Central, shared across issuers | Contract per issuer per merchant |
| How acceptance is limited | Merchant category | Accredited merchant network | Contracted merchants |
| Daily ceiling | 7.67 EUR subsidy per meal | 25 EUR of spending | 10 EUR exempt, electronic |
For a programme designer the German rule set is the simplest of the three to implement and the hardest to defend commercially, because nothing stops the next entrant doing the same thing.
Every dated change across Europe sits on the 2025 to 2028 calendar. The mechanics of restriction are covered in how a meal voucher card works.