By Rav Avrohom Dovid Waxman
Shulchan Aruch (Orach Chaim 273:1) states that Kiddush must be recited Bmakom Seudah, in the place where one eats the meal. The Mishna Berurah explains by quoting the Rashbam in Pesachim 101a based on the Pasuk: Vkarasa Lshabbos Oneg (You call the Shabbos delight) that in the same place of Oneg meaning the Seuda, one must recite Kiddush. The Rema (273:3) adds that one must eat in the place of Kiddush immediately.
The Gemara Pesachim ((101a) records a story. When Abaya was in the house of Rabbah, Rabbah would recite Kiddush and tell the students: Taste some food here lest by the time you get to your lodging, your lights will be extinguished and you will not be able to recite Kiddush in the place where you eat. And with the Kiddush you heard here you do not fulfil the Mitzva as there is no kiddush except Bmakom Seudah.
Tosfos interprets the statement “Taste some food” to mean Bread. The Rosh (Arvei Pesachim 5) interprets it that way as well.
Shulchan Aruch (Orach Chaim 273:5) quotes the Geonim that even if one only ate a little bit or drank a Kos of wine in the place where Kiddush was recited, he is in fulfillment of Mitzvas Kiddush. Magen Avraham (11) maintains that if one ate cake, that suffices as well. The Geonim understood the Gemara in Pesachim (ibid) to be referring to tasting something, and not necessarily bread.
Mekor Chaim (by the author of Chavos Yair,273:5) and Ein Yitzchak (Rav Yitzchak Elchanan Spektor Z”L, Orach Chaim 12) interpret Tosfos and the Rosh to mean that one must eat bread to fulfill the obligation of Kiddush Bmakom Seudah. They are arguing on the opinion of the Geonim that bread is not required. (see Beis Yosef that maintains Tosfos and the Rosh agree with the Geonim, and only require bread for the obligation of Seudas Shabbos and not the Halacha of Kiddush Bmakom Seudah).
Hagaos Rav Akiva Eiger (ibid) quotes Rabeinu Yona in Brachos that holds that one must have bread to fulfill the Halacha of Kiddush Bmakom Seuda.
The Biur Halacha (ibid) quotes Maseh Rav that the Vilna Gaon was careful to recite Kiddush in the place where he ate bread and would not rely on the opinion of the Geonim even for the daytime Kidddush.
The Minhag Haolam is to be lenient during the daytime Kiddush which is Miderabanan and rely on the Geonim that cake is enough to fulfill the Halacha of Kiddush Bmakom Seudah. However, regarding Friday night Kiddush, which is Min Hatorah; Ein Yitzchak (ibid) and Ginas Vradim (13:12) write that one should be Machmir to eat bread immediately after Kiddush and not cake. (see also Shaar Hatzion 273:29 that one should be Machmir regarding Kiddush at night not to drink a Kos of wine to fulfill the obligation of Kiddush Bmakom Seudah.)
Despite the fact that one can theoretically fulfill the obligation of Kiddush Min Hatorah through Tefilah. Teshuvos Chasam Sofer (Orach Chaim 17 and 21) writes that if one knows that he has wine and a Seudah available at home then it’s “Klev Beis Din Masneh”, it’s as if Beis Din implicitly stipulates that one does not want to fulfill the Mitzva through Tefilah. Rather one fulfills the Mitzva as Chazal instituted it, with wine Bmakom Seudah. Therefore, reciting Kiddush on Friday night with wine is actually Min Hatorah.
Regarding Kiddush at night on Yom Tov which is Medrabanan (see Magid Mishna Shabbos 29:18 and Magen Avraham 271:1) one can be lenient like the opinion of the Geonim that bread is not required for the Halacha of Kiddush Bmakom Seudah.
May we be Zoche that Hashem should bring the Geula Shilaima Bimheira Biyameinu.
By Rav Avrohom Dovid Waxman R”M Yeshivas Mishkan Hatorah Lakewood and author of Seforim Minchas Halevi.
Adapted by Yosef Reuven Sheinfeld