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Acquiring for Sole Proprietorships in Ukraine: How It Works, ECR/PECR Requirements, Taxes, Receipts, and Penalties

02.11.2026 10:13
Andrii Toverovskyi
Andrii Toverovskyi

Expert in tax and legal business matters

Acquiring allows entrepreneurs to accept payments by card and other electronic payment instruments through a POS terminal, smartphone, website, or another payment solution. A store or Sole Proprietorship does not need a separate «acquiring license»: acquiring is a payment service provided by an authorized payment service provider, and the merchant uses it under an agreement. The law requires merchants to offer cashless payment options within the deadlines established by the Cabinet of Ministers, but it does not require every merchant to purchase a physical POS terminal.

Entrepreneurs should distinguish between acquiring and fiscalization. A card payment through acquiring is cashless, but under the ECR Law, it is generally considered a settlement transaction. If a Sole Proprietorship is required to use an ECR/PECR, the card payment must be fiscalized and the customer must receive a fiscal receipt. A POS terminal receipt does not replace a fiscal receipt. For a Sole Proprietorship paying the single tax, income from acquiring transactions accompanied by a fiscal receipt is the full purchase amount before deduction of the bank commission, and the income recognition date is the date on the fiscal receipt.

What Is Acquiring?

The Law of Ukraine «On Payment Services» defines the acquiring of payment instruments as a payment service that results, among other things, in the transfer of funds to the recipient for transactions made using payment instruments. The acquirer provides this service to the merchant under an agreement. The merchant pays acquiring fees according to the terms of that agreement.

A typical card transaction involves:

  • customer — initiates the payment;

  • merchant — sells goods or services and accepts the cashless payment;

  • payment instrument issuer — the payment service provider that issued the customer's card or other electronic payment instrument;

  • acquirer — the payment service provider that serves the merchant and enables payment acceptance;

  • payment system and its participants — process the transaction according to the rules of the relevant system.

The acquirer does not necessarily have to be a bank. Non-bank institutions may also provide the relevant financial payment services after authorization by the National Bank of Ukraine and, depending on their status, obtaining the necessary license. Providers can be checked in the NBU Payment Infrastructure Register.

How Payments Through Acquiring Work

Several operations take place during an ordinary card purchase. The customer taps a card or smartphone on the terminal, inserts a card, or enters payment details on a payment page. The information is submitted for payment authorization, after which the transaction is approved or declined. Following a successful transaction, the merchant receives funds according to the settlement periods and rules established in the agreement with the acquirer.

Therefore, there is no general statutory rule requiring acquiring proceeds to be credited to an entrepreneur «instantly» or within one particular period. Settlement periods, commissions, refunds, technical requirements, and other conditions are determined by the agreement with the payment service provider.

Types of Acquiring

The law does not establish a separate legal classification into «in-store», «mobile», and «internet acquiring», but businesses should distinguish between the technical methods used to accept payments.

OptionHow Payment Is MadeWhere It Is Used
In-store acquiring A card, smartphone, or other electronic payment instrument is used through a POS terminal Stores, cafés, salons, offices, service locations
SoftPOS / Tap to Phone A compatible smartphone or other device is used as a payment device Mobile trading, couriers, small stores, mobile sales points
Internet acquiring A card transaction is processed on a website, in an app, or through a payment link Online stores, online services
QR code or payment link A QR code or link initiates a particular payment mechanism Offline and online sales

A QR code does not, by itself, determine the type of payment. It may lead to an internet acquiring page, initiate a card payment, or contain details for a bank transfer to an IBAN account. These transactions may have different implications for ECR/PECR use, so the actual movement of funds must be assessed rather than the payment method's name. In particular, the State Tax Service separately distinguishes payments via POS terminals, internet acquiring, internet banking, and QR-code transfers in fiscal receipts.

Is Acquiring Mandatory for Sole Proprietorships?

The law establishes an obligation to provide customers with the option of cashless payment, rather than a universal obligation for every entrepreneur to purchase a particular POS terminal model.

Cabinet of Ministers Resolution No. 894 also applies this requirement to goods and services sold remotely. The general deadlines have already passed:

MerchantsEffective Date of the Requirement
In settlements with populations exceeding 25,000 January 1, 2023
In settlements with populations of 5,000 to 25,000 January 1, 2024
In settlements with populations of up to 5,000 January 1, 2025

Therefore, for ordinary merchants, the size of a settlement is no longer grounds for failing to offer cashless payments.

Who Is Subject to a Special Deadline?

The obligation will take effect three months after the termination or cancellation of martial law for:

  • Sole Proprietorships paying the single tax in Group 1;

  • merchants using vending machines;

  • merchants conducting mobile or temporary outdoor trading;

  • merchants selling products they have grown or raised themselves.

At the end of 2025, the Cabinet of Ministers replaced the former date of «January 1, 2026» for these categories with the deadline «three months after the termination or cancellation of martial law».

A separate exemption applies to merchants operating in communities located in combat zones, temporarily occupied territories, or areas under encirclement or blockade, according to the established list. The requirement also does not apply for three months following the end of hostilities, de-occupation, or the lifting of encirclement or blockade in the relevant territory.

Is a Physical POS Terminal Mandatory?

No. Part 28 of Article 38 of the Law «On Payment Services» refers to enabling cashless payments, including through electronic payment instruments, payment applications, or payment devices. Resolution No. 894 uses a similar approach. Therefore, legislation does not make a physical stationary POS terminal the only permitted technical means of meeting the requirement.

At the same time, if a merchant offers payment using electronic payment instruments operated within payment systems, the merchant must support electronic payment instruments from at least three payment systems, one of which must be a multi-issuer payment system established by a resident of Ukraine.

Does a Sole Proprietorship Need an Acquiring License?

A Sole Proprietorship or company that merely accepts payments for its own goods or services does not thereby become a payment service provider and is not required to obtain an acquirer's license.

Authorization and licensing requirements apply to the provider of the financial payment service itself. The NBU authorizes relevant payment market participants by entering their details in the Payment Infrastructure Register and, where required, issuing licenses to provide financial payment services.

For the merchant, the main legal document is the agreement with the acquirer. There is no single statutory «POS terminal document package» applicable to all banks and payment institutions: the information and documents required for customer identification and connection of a sales outlet or website are determined by legislation, provider rules, and the agreement.

To protect the business, before signing the agreement, check at least the amount and procedure for changing commissions, settlement periods, refund terms, transaction dispute procedures, equipment purchase or rental costs, technical support, and contract termination terms.

Acquiring and ECR/PECR: When Is a Fiscal Receipt Required?

Law No. 265/95-VR classifies transactions using payment cards, among others, as settlement transactions. Businesses required to use an ECR/PECR must process the full purchase amount and provide customers with a settlement document in the prescribed form. This also applies to goods and services ordered or paid for online.

The main scenarios are:

Method of Receiving FundsECR/PECR
Card payment through a POS terminal Required unless the entrepreneur has a statutory exemption from ECR/PECR use
SoftPOS / card payment through a payment device The same general rule applies as for a card settlement transaction
Internet acquiring for goods sales An ECR/PECR is generally required unless the seller is exempt
Independent bank transfer by the buyer using the full current account details in IBAN format According to the State Tax Service's approach, this is not a settlement transaction under Law No. 265; an ECR/PECR is not required
Payments for services made exclusively through remote banking systems and/or money transfer services A special exemption applies under paragraph 14 of Article 9 of Law No. 265
Group 1 single-tax Sole Proprietorship Does not use an ECR/PECR under paragraph 296.10 of the Tax Code of Ukraine

Thus, a «cashless payment» and a «payment for which an ECR is not required» are not the same thing. Card payments through acquiring are cashless, but they are settlement transactions under Law No. 265. An independent transfer made by a buyer using IBAN details has a different treatment.

Group 1 Sole Proprietorships: Cashless Payments and ECR Requirements Are Separate Obligations

Paragraph 296.10 of the Tax Code exempts Group 1 single-tax payers from using an ECR/PECR. At the same time, Resolution No. 894 separately establishes when such Sole Proprietorships must offer cashless payments. These are two distinct legal obligations, and the requirement to accept cashless payments does not eliminate the ECR exemption provided by the Tax Code.

Internet Acquiring and Sales Through a Website

If a customer orders goods online and pays by card or through a payment service, a seller who is required to use an ECR/PECR must fiscalize the transaction and provide a fiscal receipt. The law permits receipts to be issued not only on paper but also electronically, including by sending them to a provided telephone number or email address or allowing the customer to scan the settlement document's QR code.

The State Tax Service separately explains situations where the place of settlement cannot be determined, for example, when computer software, electronic books, certificates, reports, or other digital products are supplied exclusively electronically without a physical collection point. In such cases, the State Tax Service considers an ECR/PECR optional. This exception does not apply to ordinary physical goods subsequently handed over or delivered to the buyer.

When to Issue a Receipt if Online Payment Arrives at Night or on a Day Off

For internet acquiring payments whose details arrive after working hours or on a day off, the State Tax Service's Public Information Resource provides the following procedure: the transaction must be fiscalized no later than the next working day using information on the movement of funds and observing chronological order, but in any event no later than the delivery of the purchased goods to the customer.

For an online store, this means that order acceptance, payment confirmation, receipt generation, and handover to a delivery service must be organized as a single controlled process.

A POS Terminal Receipt and a Fiscal Receipt Are Different Documents

A POS terminal receipt or transaction slip confirms a card payment transaction. It is not a fiscal settlement document generated by an ECR or PECR and therefore does not replace a fiscal receipt.

When paying by card, a customer may receive:

  1. a payment terminal document — confirmation of the card transaction;

  2. an ECR/PECR fiscal receipt — a document confirming the settlement transaction under Law No. 265.

This does not mean that a POS terminal «prints two fiscal receipts». The fiscal document is the one generated by the appropriate ECR/PECR.

Must a POS Terminal Be Connected to an ECR/PECR?

Legislation does not establish a general obligation to technically connect a POS terminal to an ECR or PECR. The State Tax Service explicitly states that separate POS terminals and ECR/PECR devices may be used.

If a payment terminal is connected to or integrated with an ECR/PECR, the fiscal receipt for the card transaction must include lines 12–17 required by Regulation No. 13, including the acquirer and merchant identifiers, payment device identifier, transaction type, permitted electronic payment instrument details, and other required information. If the terminal is not connected to the ECR/PECR, the absence of these lines does not itself constitute a violation.

For internet acquiring without a physical payment terminal, the State Tax Service also does not require lines 12–17 to be printed merely because the software technically allows the relevant details to be entered manually.

How to Show the Payment Method Correctly on a Fiscal Receipt

Following amendments to Regulation No. 13, a fiscal receipt separately identifies the payment form and the payment instrument used. For card and online transactions, the payment form is shown as cashless, while the payment instrument must correspond to the actual payment mechanism: card, in-store acquiring, internet acquiring, internet banking, QR-code transfer, and so on.

For entrepreneurs, this matters beyond formal compliance. Correctly configured payment methods make it possible to reconcile fiscal receipts, acquirer reports, and actual bank account credits.

Tax Treatment of Acquiring for Single-Tax Sole Proprietorships

For a Sole Proprietorship paying the single tax that accepts card payments through in-store or internet acquiring and issues a fiscal receipt, the State Tax Service applies the following rules:

  • income includes the full amount paid by the customer, not the amount remaining after the bank commission is deducted;

  • the acquirer's commission does not reduce the single-tax payer's income;

  • the date of receiving this income is the date shown on the fiscal receipt.

Example

A customer pays UAH 1,000 for goods by card. Under the agreement, the acquirer deducts a UAH 20 commission and transfers UAH 980 to the entrepreneur.

For a Sole Proprietorship paying the single tax, the income from this sale is UAH 1,000, not UAH 980. The income date is the fiscal receipt date. The State Tax Service confirmed this approach, in particular, in its explanation dated July 2, 2026, concerning in-store and internet acquiring.

This is important for monitoring income limits and completing tax returns correctly: reconciling taxable income only against the bank's «net» credits after commission deductions is incorrect.

Acquiring for Sole Proprietorships Under the General Taxation System

For Sole Proprietorships under the general taxation system, the State Tax Service also considers the full revenue amount, including the commission withheld by the bank or another acquirer, to be income from an acquiring transaction. If a fiscal receipt was generated, the income date is the date of that receipt.

However, the taxable base for a Sole Proprietorship under the general taxation system is net taxable income — the difference between total income and documented expenses that may be deducted under Article 177 of the Tax Code of Ukraine. The Code includes fees for banking and cash management services among other expenses related to business activities. Therefore, expenses for banking and payment services should be substantiated by agreements, statements, and other appropriate documents and accounted for according to their actual legal nature.

Acquiring and VAT

Acquiring itself does not establish a separate VAT rate or special VAT treatment. VAT payers determine their tax liabilities according to Section V of the Tax Code.

Under the general rule in paragraph 187.1 of the Tax Code, VAT liabilities arise on the earlier of two events — receipt of payment or supply of goods/services. The taxable base is determined under Article 188 of the Tax Code based on the contractual value, subject to the limitations established by the Code. Therefore, the acquirer's deduction of its commission does not automatically reduce the contractual value of the goods purchased by the customer.

Refunding Customers After Card Payments

If the original sale was fiscalized, the refund must also be properly processed through an ECR/PECR. For PECRs, the State Tax Service provides for recording a negative amount — generating a refund receipt that specifies the fiscal number of the document associated with the refund.

Separately from fiscal processing, the payment refund itself must be completed according to the acquirer's rules and agreement. Therefore, it is not enough for a cashier merely to cancel the sale in the inventory management software: both the fiscal document and the actual refund through the payment infrastructure must be checked.

What Merchants Are Prohibited From Doing When Accepting Card Payments

Article 38 of the Law «On Payment Services» expressly prohibits merchants from:

  • restricting a customer's right to choose an electronic payment instrument from those the merchant is required to accept;

  • charging customers an additional fee because they pay using an electronic payment instrument, payment application, or payment device;

  • setting different prices for the same goods or services depending on whether the customer pays in cash or by cashless means.

For example, a condition such as «+2% to the price when paying by card» to compensate the merchant for the acquiring commission directly contradicts this statutory prohibition. The entrepreneur should account for acquiring costs in their sales economics rather than passing them on to a particular customer as a separate card payment surcharge.

At the same time, the law allows merchants to encourage customers to use particular electronic payment instruments.

Penalties for Violating Cashless Payment and ECR Rules

For failure to comply with statutory requirements to enable payments using electronic payment instruments, Article 163-15 of the Code of Ukraine on Administrative Offenses provides for an administrative fine:

ViolationAmount
First violation 100 to 200 non-taxable minimum incomes of citizens
Repeated within one year after a penalty has been imposed 500 to 1,000 non-taxable minimums

For calculating this fine, one non-taxable minimum equals UAH 17. Thus, the fine is UAH 1,700–3,400 for the first violation and UAH 8,500–17,000 for a repeated violation.

Separate financial penalties apply for violations of Law No. 265 concerning ECR/PECR use. Paragraph 1 of Article 17 provides the following penalties for processing a settlement transaction without an ECR/PECR, for less than the full amount, or without providing the required settlement document:

  • 100% of the value of goods, works, or services sold in violation of the rules — for the first violation;

  • 150% of the value — for each subsequent violation.

These are different types of liability. An administrative fine for violating cashless payment requirements does not replace financial penalties for violating ECR/PECR rules.

How to Set Up Acquiring Without Unnecessary Tax Risks

Before launching card payments, organize the process so that each transaction can be identified consistently in the POS system, PECR, acquirer report, and bank statement.

A practical procedure:

  1. Check the payment service provider in the NBU registers.

  2. Sign an agreement and review commissions, settlement periods, and refund procedures.

  3. Identify every payment channel: POS, SoftPOS, website, payment links, and IBAN.

  4. Determine separately whether transactions through each channel are settlement transactions under Law No. 265.

  5. Configure the correct payment form and instrument in the ECR/PECR.

  6. Verify that card transaction details are transmitted correctly when using an integrated POS terminal.

  7. Perform a test sale and a test refund.

  8. Daily, or at intervals defined by the internal process, reconcile total fiscal sales, acquirer reports, bank credits, and withheld commissions.

  9. For tax accounting purposes, do not substitute the amount credited by the bank after the acquiring commission for the actual revenue.

Acquiring in Torgsoft: Automatic Payments Through Bank Terminals, PECR, and Commission Accounting

Torgsoft offers the Bank Payment Terminal Integration feature, which automates card payments for goods and refund operations. When a sale is processed, the software can automatically send the amount to the bank terminal, reducing the risk of cashiers manually entering the wrong amount. Torgsoft's documentation describes support for various bank terminal integration protocols, including BPOS, JSON, PosApi, SimPays/InpasEcrCom, OschadPAY, and others.

The PECR in Torgsoft allows cashless payment instruments to be configured separately for transactions processed through a bank terminal and for other cashless transactions. For payments through an integrated bank terminal, transaction information may be displayed on the receipt. If the automatic connection to the terminal is temporarily unavailable, the software provides an option to enter the payment details manually.

For financial control, Torgsoft records sales revenue and acquiring commissions separately. Financial analysis includes an «Acquiring» category to which bank commissions on card payments are automatically allocated. This makes it possible to see the full sales amount separately from the cost of the banking service and avoid confusing the «net» amount credited to the account with the business's actual sales revenue.

Key Points About Acquiring for Sole Proprietorships

Acquiring is a payment service, not a replacement for a cash register or PECR. Sole Proprietorships do not need a separate license to accept card payments, but the acquirer must be properly authorized. For most merchants, the obligation to offer cashless payments is already in effect regardless of settlement size. A special deadline applies to Group 1 Sole Proprietorships, vending machines, mobile trading, and the sale of self-grown or self-raised products.

Card payments through POS terminals or internet acquiring generally require fiscalization if the entrepreneur is obliged to use an ECR/PECR. A bank terminal slip does not replace a fiscal receipt. An independent bank transfer made by the customer using full IBAN details has a different legal treatment and is not acquiring.

For single-tax Sole Proprietorships using acquiring with a fiscal receipt, income is the full sales amount, including the acquirer's commission, and the income date is the fiscal receipt date. An entrepreneur may not charge a card payment surcharge or set a higher cashless price for the same product.

Official Sources

  • Law of Ukraine «On Payment Services» dated June 30, 2021, No. 1591-IX — Articles 1, 29, 37, and 38: definition of acquiring, payment service agreements, acquiring procedures, the obligation to offer cashless payments, payment system requirements, and the prohibition on card payment surcharges. Law No. 1591-IX on the Verkhovna Rada of Ukraine website

  • Resolution of the Cabinet of Ministers of Ukraine dated July 29, 2022, No. 894 — paragraphs 1–2: deadlines for introducing cashless payment options and territorial exemptions. Resolution No. 894 on the Verkhovna Rada of Ukraine website

  • Resolution of the Cabinet of Ministers of Ukraine dated December 29, 2025, No. 1768 — postponement of the deadline for Group 1 Sole Proprietorships, vending machines, mobile trading, and sales of self-grown or self-raised products until three months after the termination or cancellation of martial law. Resolution No. 1768 on the Verkhovna Rada of Ukraine website

  • Law of Ukraine «On the Use of Registrars of Settlement Transactions in Trade, Catering and Services» dated July 6, 1995, No. 265/95-VR — Articles 2, 3, 9, and 17: definition of settlement transactions, obligation to use ECR/PECR, exemptions, and financial penalties. Law No. 265/95-VR on the Verkhovna Rada of Ukraine website

  • Order of the Ministry of Finance of Ukraine dated January 21, 2016, No. 13 — Regulation on the form and content of settlement documents; Sections I–II and form FCR-1: fiscal receipt details, payment form and instrument, transaction details for a connected or integrated payment terminal. Ministry of Finance Order No. 13 on the Verkhovna Rada of Ukraine website

  • Tax Code of Ukraine dated December 2, 2010, No. 2755-VI — Articles 177, 187, 188, and 292; paragraph 296.10; paragraph 5 of Subsection 1, Section XX: taxation of Sole Proprietorships, VAT, single tax, Group 1 exemption from ECR use, and the value of the non-taxable minimum. Tax Code of Ukraine

  • Code of Ukraine on Administrative Offenses dated December 7, 1984, No. 8073-X — Article 163-15: liability for violating requirements concerning payments using electronic payment instruments. Code on Administrative Offenses on the Verkhovna Rada of Ukraine website

  • Law of Ukraine «On Consumer Protection» dated May 12, 1991, No. 1023-XII — Article 17: consumers' right to make cashless payments freely where provided for by law. Law No. 1023-XII on the Verkhovna Rada of Ukraine website

  • Law of Ukraine «On Electronic Commerce» dated September 3, 2015, No. 675-VIII — Article 13: payment methods in electronic commerce and documentary confirmation of receiving funds. Law No. 675-VIII on the Verkhovna Rada of Ukraine website

  • National Bank of Ukraine — authorization of payment service providers and the Payment Infrastructure Register: official information for verifying the status of bank and non-bank payment service providers. NBU Payment Infrastructure Register and Payment Market Participant Authorization

  • State Tax Service of Ukraine — Public Information Resource: official explanations concerning ECR/PECR, acquiring, payment forms, refunds, and internet trading. State Tax Service Public Information Resource

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