Implementation Center · Step 5 of 6

    Document the policy

    A written internal policy is what ties the rule, the POS configuration, employee training, and customer communication together, and gives the business something concrete to point to later. This page explains why that matters and what it typically covers.

    H.R. 10167 — Passed Congress. Passed House and Senate. Awaiting presentation to the President. Last verified 2026-09-29. Track current status

    H.R. 10167 has not been signed into law. Both chambers of Congress have passed H.R. 10167 in the same form. It becomes law only after presidential action. It is not in force today. This page describes the bill as passed by Congress so businesses can prepare; nothing here is a current legal requirement.

    Why write it down

    The federal safe harbor in Section 4 protects adherence to the Section 3 method. Primary source Adherence is easier to demonstrate when it is documented: what rule the business follows, how it is configured, and what happened when something deviated from the default. Centsless analysis A policy is not a legal filing, it is an internal reference document.

    Suggested components

    Effective date

    When the policy takes effect at each location. Implementation consideration

    Applicable locations

    Which locations the policy covers, if the business operates more than one. Implementation consideration

    Qualifying transactions

    Which transactions are cash and eligible for rounding, per the bill's covered-amount definition. Implementation consideration

    POS configuration

    How the point-of-sale system is configured to apply rounding, referencing the questions verified in Configure the POS. Implementation consideration

    Employee procedures

    What cashiers and managers are expected to do, referencing the training in Train Employees. Implementation consideration

    Customer communication

    What signage, receipt language, and FAQ content is in use, referencing Communicate with Customers. Implementation consideration

    Exceptions

    Any situations where rounding does not apply, such as excluded payment methods or locations still awaiting configuration. Implementation consideration

    Reconciliation

    How rounding adjustments are reconciled against exact-cent totals in accounting records. Implementation consideration

    Audit and documentation practices

    What records are retained to show the rule applied and when. Implementation consideration

    Review schedule

    When the policy will be reviewed, particularly as the federal bill's status changes. Implementation consideration

    Records that support the policy

    A per-transaction record that can show the rule applied gives the policy something to stand on. Fields a business may want to capture include: Implementation consideration

    • Exact transaction amount
    • Tax amount
    • Covered amount and basis
    • Tender
    • Jurisdiction
    • Rule and version applied
    • Effective date
    • Authority
    • Rounding adjustment
    • Final cash settlement
    • Decision timestamp
    • Reason the rule applied
    • Evidence classification

    This list reflects planning considerations informed by the bill's structure, not a record-keeping format the bill itself specifies. Centsless analysis

    Next: draft the policy

    A fill-in outline built around these components is available on the Cash Rounding Policy Template page. It is provided for operational planning and does not constitute legal advice.