Compliance Analysis
Cross-jurisdictional risk scoring, conflict mapping, and model statutory language for the U.S. cash rounding transition. 21 states have enacted cash-rounding authority, including 21 merchant or broader frameworks. California carries AB 1793 (merchants, signed September 30, 2026, operative July 1, 2027) and the separate SB 1005 authority (local agencies, in force). Scope, obligation structure, tax treatment, and mixed tender handling differ.
Official sources only · Last verified: October 1, 2026. California AB 1793 signing recorded September 30, 2026; SB 1005 verified against the chaptered act and official bill history. · 2026.10.01
Based on 49 tracked bills across 37 states. See the full Legislation Tracker for bill status and progression counts.
21 states have enacted cash-rounding authority.
The total includes 21 merchant or broader frameworks. In California, AB 1793 obligates merchants from July 1, 2027, while SB 1005 separately covers participating local agencies. 0 merchant or broader frameworks are in force and 21 are counting down.
See the live enactment board on the Legislation Tracker.
Federal Permission Is Not a Federal Standard
The Common Cents Act has passed Congress and awaits presidential action. It is not yet law. As drafted it permits rounding and creates safe harbor protections for good-faith operators. It does not standardize rounding methods and does not displace state authority. 21 states have merchant or broader enacted frameworks, including California AB 1793, operative July 1, 2027. California also has an in-force local-agency authority under SB 1005. Most enacted merchant frameworks require tax calculated and remitted on the pre-rounded amount. Georgia, Hawaii and Indiana round a tax-inclusive total, and Minnesota does not address tax computation. Safe harbor operates as a protection an operator must be able to substantiate: demonstrating good-faith rounding under the applicable rules requires a per-transaction record of which rule applied and how. The compliance question for multi-state operators is unchanged by congressional passage.
New York: the collision case
New York is positioned to become the most complex rounding jurisdiction in the country. Its rounding bill has passed both chambers and awaits the Governor, while a separately enacted cash acceptance law already prohibits charging cash customers more than customers using other payment methods. Symmetrical rounding can round a cash total up, which creates direct tension with the cash discrimination standard. Operators in New York will need transaction level documentation showing rounding methodology and direction to defend disparate treatment claims.
California update: the largest retail market in the country now has two enacted authorities. SB 1005 (local agencies) took effect September 18, 2026, and AB 1793 (merchants) was signed September 30, 2026 and becomes operative July 1, 2027. Both are state frameworks that may need to be evaluated alongside the federal Common Cents Act.
Legislative Lifecycle
Distribution of 28 states with active legislation, meaning tracked states excluding guidance-only and failed across the legislative progression model.
Acceleration Signals
Signal-based alerts on states crossing material compliance thresholds.
- Alert
Senate passed H.R. 10167 without amendment by unanimous consent September 28, 2026, after the Senate Banking Committee was discharged. The bill has cleared Congress and awaits presentation to the President. It is not yet law.
2026-09-28
- Alert
H.R. 10167 passed the House by voice vote September 14, 2026, then was received in the Senate and referred to Senate Banking September 15. It was then pending Senate committee action.
2026-09-15
- Alert
Senate passed S. 1525, the Common Cents Act companion bill, by unanimous consent. Received in the House August 10, 2026 and awaiting further House action.
2026-08-07
- Alert
Missouri rounding law signed by Governor Kehoe. 20th state to enact cash rounding. Effective August 28, 2026.
2026-07-13
- Alert
Hawaii SB 3255 signed into law as Act 159. 19th state to enact cash rounding.
2026-06-25
- Alert
Vermont S.327 signed by Governor Scott. 18th state to enact cash rounding.
2026-06-08
- Alert
Connecticut HB 5349 signed as Public Act 26-128. Effective January 2027.
2026-06-04
- Alert
New York passed both chambers; Senate final passage. Bill headed to Governor Hochul.
2026-06-03
- Info
Minnesota enacted state-agency cash rounding via Laws 2026 Chapter 119.
2026-05-27
- Info
Kentucky enacted government cash rounding via HB 757 / Acts Chapter 161.
2026-04-14
Obligation Structure Across 21 Enacted States
Four states obligate merchants to round: Arizona, California, Georgia and Indiana. Each state is counted once. New Mexico appears in the delegation row only. Kentucky and Oklahoma appear in the split row only.
4
Obligates merchants
Arizona, California, Georgia, Indiana
2
Obligates government payees, permits private
Kentucky, Oklahoma
14
Permissive
Alabama, Connecticut, Florida, Hawaii, Idaho, Maryland, Minnesota, Missouri, Nebraska, Oregon, Tennessee, Vermont, Virginia, Washington
1
Delegation to an agency
New Mexico
Arizona
Requires Swedish rounding when one-cent coins are unavailable, prohibits any other method, requires a posted notice at the point of sale, and requires taxes and fees remitted on the pre-rounding sales price. Enforcement sits with the Weights and Measures Services Division of the Department of Agriculture, which may impose civil penalties.
Georgia
Obligates merchants on in-person general retail sales, effective July 1, 2026. Rounding applies to a tax-inclusive total, with the sales price preserved by a separate clause.
Indiana
Obligates business entities including banks, and government units. Operator-choice rounding, up or down, applied to the total including tax under IC 23-15-13-3. Amounts added or subtracted to comply with the rounding chapter are excluded from gross retail income under IC 6-2.5-1-5(f). Rounding applies to cash transactions occurring after December 31, 2026.
Connecticut
Public Act 26-128 requires a merchant to determine total price in a prescribed manner and permits the rounding step inside that method. Reaches in-person retail only and exempts totals of four cents or less. The rounding section is effective January 1, 2027.
Florida
Permissive rather than mandatory, and conditioned: s. 212.12(10)(c)2 authorises a sales tax dealer to round an in-person cash transaction to the nearest nickel where the one-cent piece is no longer in production. Merchants within that condition may opt in or out, so the consumer experience varies across the state. A separate secondhand dealer provision at s. 538.235 is mandatory in that narrow context.
Most enacted states require tax calculated and remitted on the pre-rounded amount. Georgia, Hawaii and Indiana round a tax-inclusive total, and Minnesota does not address tax computation.
Liability Protection in the Enacted Text
Three tiers of protection appear across the enacted statutes. None of these provisions preempts federal law and none operates as a general immunity.
Reaching a private cause of action, by naming the statute
- Florida: Exempt from the Florida Deceptive and Unfair Trade Practices Act (s. 501.212).
- Hawaii: Not subject to the private remedy at s. 486-116.
- Oregon: No liability under the Unlawful Trade Practices Act (ORS 646.605 to 646.652); also ORS 618.236.
- Tennessee: Exempt under the Consumer Protection Act of 1977 (T.C.A. 47-18-111(a)).
- Vermont: Rounding does not constitute an unfair or deceptive act or practice in commerce.
- Washington: Narrow. A rounded price inconsistent with a displayed or advertised price is not actionable under the Consumer Protection Act (RCW 19.86). Other theories are not covered.
Regulatory cover only
Arizona, Georgia, Kentucky, Missouri, Nebraska, Virginia
No liability protection in the enacted text
Alabama, California, Connecticut, Idaho, Indiana, Maryland, Minnesota, New Mexico, Oklahoma
Local preemption, a separate feature
- Maryland: Chapters 516 and 515 supersede conflicting local regulations, rules and ordinances.
- Washington: Declares rounding a matter of statewide concern, preempts local measures restricting it, and bars a local government from treating lawful rounding as a surcharge or an unlawful price differential based on payment method.
Virginia caveat
The safe harbor at Va. Code s. 6.2-200.2(B) protects action taken in compliance with that section. Section 6.2-200.2 is the tax-calculation provision. The rounding authority is s. 6.2-200.1. Operators relying on the Virginia safe harbor should read both sections.
Mixed Tender Treatment
At least seven distinct approaches exist across the 21 enacted states.
Approach 1
Cash portion only
Alabama, California, Tennessee, Washington, Oklahoma
Rounding reaches the cash portion of the transaction and nothing else.
Approach 2
Order of tender
Oregon
Cash first then card means no rounding on any part of the transaction. Card first with cash closing means the remainder rounds.
Approach 3
Non-cash applied first, remainder payable in cash
Nebraska
The non-cash amount is applied first and the cash remainder is what rounds.
Approach 4
Excluded unless cash is disbursed to the purchaser
Georgia, Florida
Split transactions fall outside the rounding rule unless cash goes back to the purchaser.
Approach 5
Whole total rounded after tax where any part is cash
Vermont
Any cash component pulls the entire post-tax total into rounding.
Approach 6
Non-cash methods excluded, split transactions not addressed
Arizona, Hawaii, Minnesota
The statute excludes non-cash methods and is silent on split tender.
Approach 7
Total-amount rule with no split provision
Indiana
The rule attaches to the total amount and the act contains no split-tender provision.
Smallest Transaction Handling
Totals of one to four cents are treated four different ways across the enacted statutes.
Rounds up to five cents
Georgia, Hawaii, Maryland, Minnesota, Nebraska
Rounds down to zero
Arizona, Florida, Kentucky, Oklahoma, Tennessee, Washington
Exempt from rounding
Connecticut (totals of four cents or less)
Totals of two cents or less excluded
California
Merchant may round to either zero or five
Indiana
Compliance Conflicts
Situations where two enacted requirements pull against each other. State by state obligations, mixed tender handling, and smallest transaction treatment are covered in the sections above. The New York rounding versus cash acceptance collision is covered in the Cross-Jurisdiction Conflict section.
Virginia
SAFE HARBOR ATTACHES TO THE ADJACENT SECTIONThe safe harbor at Va. Code s. 6.2-200.2(B) protects action taken in compliance with that section, which is the tax-calculation provision. The rounding authority sits at s. 6.2-200.1. An operator relying on the Virginia shield should read both sections, because the protection does not plainly attach to the rounding step itself.
Tax Treatment Complexity
State-level divergence in how rounding interacts with tax calculation creates significant compliance complexity for multi-state retailers and POS systems.
Tax included before rounding
The total including tax is rounded as a single amount. Georgia, Hawaii and Indiana.
Tax calculated first, then total rounded
Tax is computed on the pre-rounded amount and rounding applies to the final total. This is the majority position across the enacted states.
Exact tax remittance required regardless of rounding
The exact computed tax must be remitted whether the cash total rounds up or down. Missouri, Tennessee and Washington.
Tax computation not addressed
The enacted text is silent on how rounding interacts with tax computation. Minnesota.
Most enacted states require tax calculated and remitted on the pre-rounded amount. Georgia, Hawaii and Indiana round a tax-inclusive total, and Minnesota does not address tax computation. Multi-state operators must configure point of sale behavior to match each jurisdiction.
Massachusetts Department of Revenue Directive DD 26-1 (May 5, 2026), issued in coordination with Division of Standards guidance and alongside Rep. Tackey Chan's companion bill H 5138, is a recent example of the pre-rounding tax calculation model. The directive specifies that vendors must calculate sales tax on the exact sales price and remit the exact tax amount regardless of whether the cash total rounds up or down. The directive includes worked examples showing this calculation across both round-up and round-down scenarios.
Centsless is designed to adapt to jurisdiction-specific rounding and tax treatment requirements through configurable compliance logic.
Bill vs Implementation Inconsistency Dashboard
Cross-state analysis of gaps between legislative requirements and typical POS implementation behavior.
Inconsistency Heatmap
Comparison of enacted text against typical point of sale behavior. Inclusion rule: enacted states with a completed gap assessment, currently 12 of the 21 enacted states. The remaining 9 enacted states have not been assessed and are not shown; their absence is not a finding. States whose bills failed or have not been enacted are excluded, because an implementation gap cannot be assessed against text that never took effect.
| State | Tax Moment | Disclosure Gap | Returns/Refunds Gap | Change Due | Merchant Discretion | Auditability Gap | Enforcement Unclear |
|---|---|---|---|---|---|---|---|
| Alabama | |||||||
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| California | |||||||
| Florida | |||||||
| Georgia | |||||||
| Indiana | |||||||
| Maryland | |||||||
| Missouri | |||||||
| Nebraska | |||||||
| Oregon | |||||||
| Tennessee | |||||||
| Washington |
Most Common Gaps
Frequency of each gap type across the 12 assessed enacted states, of 21 enacted. Denominators are the assessed set, not the full enacted set. Counts describe gap types rather than ranking jurisdictions.
Centsless Model Language Recommendations
Generic statutory clause recommendations for each identified inconsistency type. Not state-specific.
This is drafting suggestion offered as statutory craft, not legal advice. Statutory interpretation and legal compliance remain the responsibility of the implementing entity.
Disclosure Gap
Statute should require: 'Merchants shall post visible signage at the point of sale and include a line item on printed or electronic receipts indicating any rounding adjustment applied.'
Returns/Refunds Gap
Statute should specify: 'Refunds and returns shall be processed based on the exact amount paid by the consumer, inclusive of any rounding adjustment applied at the time of the original transaction.'
Change Due vs Total Due Conflict
Statute should clarify: 'Rounding shall apply to the total amount due from the consumer, not to the change due to the consumer, to ensure consistent application across POS configurations.'
Merchant Discretion Risk
Statute should mandate: 'Where merchant participation is optional, rounding must follow symmetrical nearest-$0.05 methodology and merchants must provide consumer notice prior to applying rounding.'
Auditability Gap
Statute should require: 'Merchants shall maintain transaction-level documentation sufficient to support regulatory review of rounding adjustments, retained in accordance with applicable recordkeeping requirements.'
Enforcement Unclear
Statute should designate: 'The [state consumer protection agency] shall have enforcement authority, including the ability to investigate complaints, conduct audits, and impose civil penalties for non-compliance.'
Tax Moment Ambiguity
Statute should explicitly state: 'Rounding shall be applied only after the computation of all applicable sales taxes, use taxes, and statutory fees.'
Methodology: States included reflect bills formally introduced between November 2025 and May 2026. Companion bills consolidated under state-level entries. Federal legislation tracked separately. Selected state Department of Revenue directives and administrative guidance documents are referenced where they materially affect compliance posture, even where legislation has not passed. Centsless provides legislative monitoring and structural analysis. Statutory interpretation and legal compliance remain the responsibility of the implementing entity.
Verification: Method and scope classifications verified against the enacted, enrolled, engrossed or chaptered act, or the official bill history of the enacting chamber. Washington's enacted method is symmetric despite "asymmetrical" labeling in its legislative staff report and Governor's press release. Connecticut (PA 26-128), Minnesota (Laws 2026 Ch. 119), Oregon (Ch. 126), and New Mexico (method delegated to the Taxation and Revenue Department) have each been verified against enacted text. Three enacted states obligate merchants to round: Arizona, Georgia and Indiana. Utah remains guidance-only. The November 10, 2025 Division of Consumer Protection advisory is vertical-specific and, to our knowledge, no Utah statute exists.
Scope Breakdown
How tracked bills break down by legislative scope and category.
27
General Retail Cash Rounding
5
Government Payments Only
0
Local Agency Payments
3
Tax and Fiscal Administration
2
Mixed Scope
1
Federal
Observed Legislative Pattern (2025 to 2026)
Key structural patterns across 28 states with active legislation and 5 guidance-only states.
- 28 states have introduced or advanced cash rounding legislation with 49 total bills tracked. An additional 5 states have issued guidance without legislation.
- 21 states have enacted cash-rounding authority, including 21 merchant or broader frameworks. California AB 1793 is operative July 1, 2027; SB 1005 separately covers participating local agencies.
- 16 states are advancing companion bills across multiple legislative vehicles.
- 7 bills address government-only or mixed-scope rounding beyond general retail.
- Tax handling, scope classification, and enforcement language remain the primary points of divergence.
- No uniform national standard exists. Legislative velocity varies significantly by state.
Regulatory Divergence Index
While rounding mechanics are largely consistent, tax treatment, scope categories, and enforcement language vary across jurisdictions. This divergence, now spanning 28 states with active legislation and federal proposals, increases compliance complexity for multi-state operators.
Why this matters operationally
This page analyzes implications: obligation structure, tax treatment, liability protection, and cross-jurisdictional conflicts that follow from enacted and pending rules. Applying the right outcome to a given transaction still requires resolving which authority governs it and preserving that determination.
- Context
- Where, by whom, in which direction, and on what date the transaction occurs.
- Applicable rule
- Which rule version is in force and whether it applies to this transaction.
- Authority
- Which published source governs, and whether it is enacted, delegated, or proposed.
- Evidence
- What record explains the outcome after the fact.
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