How to Deregister a Hardware Cash Register: Documents, Deadlines, and Steps

To voluntarily deregister a hardware cash register (RRO), complete transactions and transmit reporting data, arrange for the seal to be removed by a service center (ЦСО), and submit Application No. 4-RRO to the tax authority together with the registration certificate. The tax authority deregisters the device within five calendar days of receiving the application and certificate, provided it has received from the service center the sealing certificate marked to confirm seal removal. The result is confirmed by Certificate No. 6-RRO. At the same time, the tax authority cancels registration of the book of settlement transactions (КОРО) for that device and any corresponding settlement books (РК), if registered.

This guide applies to individual entrepreneurs (ФОП) and legal entities that use hardware cash registers in Ukraine to settle payments for goods and services. Before moving a device to another store, check whether it can be re-registered. If you are switching to a software cash register (ПРРО), prepare it for upcoming sales and complete the hardware device’s procedure separately. Switching off the device or changing Torgsoft settings does not deregister it with the State Tax Service of Ukraine (ДПС). After deregistration, retain books, control tapes, and reports for the periods prescribed for each of them.

Determine whether you need to deregister or re-register the RRO

Registration of hardware cash registers used to settle payments for goods and services is governed by the Procedure approved by Order No. 547 of the Ministry of Finance of Ukraine dated 14 June 2016. Chapter 4 of Section II addresses deregistration. This Procedure does not apply to devices used to register transactions involving cash trading in currency values.

When an RRO is re-registered, its fiscal number remains the same. After deregistration, the number is closed and cannot be used again. This is established by paragraph 3 of Chapter 1 of Section II of the Procedure for Registration and Use of RROs.

If the business entity details shown in the certificate, the scope of use, or the RRO’s internal software version have changed, or if the certificate contains errors, has been lost, or is no longer usable, submit an application for re-registration within five working days following the day of the relevant event. State the reason in the application and provide the certificate if available.

A separate provision in paragraph 2 of Chapter 3 of Section II concerns changes resulting from the renaming of streets and other named places by local government decision. It requires an application marked “Перереєстрація” (“Re-registration”) and the certificate, but sets no separate filing deadline. The previous certificate ceases to be valid when a new one is issued.

To move a device to another business unit, paragraph 1 of the same chapter also requires an application marked “Перереєстрація” (“Re-registration”) and the registration certificate. If the documents are properly completed and there are no grounds for refusal, the tax authority re-registers the device no later than two working days after the application is filed. Before using it at the new store, check that the certificate identifies that store.

If the supervisory authority responsible for the taxpayer’s primary place of registration changes, paragraph 4 of Chapter 3 provides for the RRO to be re-registered through the tax service system within two working days after the taxpayer is transferred to the new authority. The previously issued certificate remains valid until the business entity details shown in it change.

If you use a КОРО together with the RRO, check its title page. A change to the address or name of the business unit, or another circumstance specified in paragraph 1 of Chapter 2 of Section II of the Procedure for books, requires the КОРО to be re-registered. Submit Application No. 1-КОРО marked “Перереєстрація” (“Re-registration”), stating the reason and providing the book, to the place where it is registered no later than five working days after the grounds arise.

For renaming streets and other named places by local government decision, that paragraph has a separate provision requiring the application and book but sets no separate deadline. The tax authority re-registers the КОРО no later than two working days from the date the application is filed. Paragraph 8 of Chapter 1 of Section III of the Procedure for Registration and Maintenance of РК and КОРО provides for the РК to be re-registered when the RRO is re-registered.

Check the grounds for deregistration

Paragraph 1 of Chapter 4 of Section II of the Procedure for Registration and Use of RROs lists 14 grounds. The numbering below corresponds to the subparagraphs of that provision:

1. The business entity submits Application No. 4-RRO to deregister the device.
2. The service life recorded in the Register of Individual RRO Units has expired. For a device that is not included in that register and was registered before the register was created, the service life in the passport or data sheet applies.
3. The operating period set by law for the RRO has ended.
4. The device is being used outside the scope specified in the State Register of RROs.
5. The modification, design, and/or internal software version does not match the information in the State Register of RROs.
6. A court decision has invalidated the business entity’s founding documents.
7. A court decision has ordered the liquidation of the business entity as a bankrupt.
8. A court decision has ordered the termination of the business entity for reasons unrelated to bankruptcy.
9. The individual entrepreneur has died, has been declared dead, has been found legally incapacitated or missing, or their civil capacity has been restricted.
10. The tax authority has received from the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Organizations information about state registration of the business entity’s termination.
11. The RRO has been stolen.
12. The RRO has a new owner.
13. The entity has notified the tax authority that the business unit where the RRO is used is closed or is no longer operated by the entity.
14. The entity has decided to stop using a hardware RRO whose service life has not yet expired because it is switching to a software RRO (ПРРО).

On grounds 1, 11, 12, and 14, deregistration is carried out on the business entity’s application. On grounds 2–10 and 13, it may be carried out either on application or compulsorily by decision of the supervisory authority where the RRO is registered. This distinction is set out in paragraph 2 of Chapter 4 of Section II of the Procedure for Registration and Use of RROs.

Prepare the till, reports, and data before seal removal

Practical recommendation: set the device’s last day of operation and designate an employee to check transactions and records. Before handing the RRO to the service center, take the following steps:

1. Complete transactions in progress. Check sales and refunds and issue the required transaction documents to customers. If the store will remain open, prepare a registered device for the next transactions.
2. Reconcile cash. If removing cash from the place of settlement, register the actual amount using the “службова видача” (“cash withdrawal”) operation. Paragraph 6 of Section III of the Procedure for Registration and Use of RROs requires cash deposits and withdrawals unrelated to settlement transactions to be registered through the device.
3. Generate the fiscal reporting receipt—the Z-report. Under paragraph 9 of Article 3 of Law No. 265/95-VR, it is generated daily if settlement transactions were carried out, except for vending machines selling goods or services. Paragraph 4 of Section III of the Procedure provides for generating the receipt at the end of the working day or shift.
4. Check that reporting data has been transmitted. For an ordinary retail RRO, paragraph 7 of Article 3 of Law No. 265/95-VR provides for electronic copies of transaction documents and fiscal reporting receipts to be transmitted through communication channels. Check the device’s messages, and contact the service center before switching it off if transmission failed.
5. Retain documents and data access. Make working copies of the certificate, service records, and reports. Decide who will retain books and electronic data after the procedure is complete.

Requirements for transactions, reporting receipts, information transmission, and control tapes are established by Article 3 of the Law of Ukraine “On the Use of Cash Registers in Trade, Public Catering and Services” No. 265/95-VR. Completing these operations does not replace filing the documents needed to deregister the device.

If you used a КОРО and РК during a repair or power outage, check that you have complied with paragraph 10 of Section III of the Procedure for Registration and Use of RROs. After a repaired or backup device is installed, or power is restored, enter through the RRO the amounts settled while using the РК, separately for each tax rate, and then generate a Z-report. If operational memory was reset, also account for control tape data for the period before the malfunction or outage. If necessary, use the “службове внесення” (“cash deposit”) operation for cash remaining at the place of settlement.

Where paragraph 7 of Article 3 of Law No. 265/95-VR requires reports to be filed in place of transmitting information through communication channels, the deadline is no later than the 15th day of the month following the reporting month. Practical recommendation: before you finish using the РК, check with your accountant whether any reports for the period of its use still need to be filed.

How to voluntarily deregister a hardware RRO

1. Arrange for seal removal by the service center

Contact the service center with which you have a technical maintenance and repair agreement for the particular RRO. Paragraph 3 of Chapter 4 of Section II of the Procedure requires the seal to be removed before deregistration. Do not remove the seals yourself.

Practical recommendation: in your request, state the model, serial number, fiscal number, and purpose—deregistration. Agree on when to hand over the device and check that the service center has sent the supervisory authority where the RRO is registered a sealing certificate marked to confirm seal removal. Paragraph 4 of Chapter 4 identifies this document. A free-form service center report cannot automatically be treated as a substitute.

2. Submit No. 4-RRO and the registration certificate

The business entity or its representative submits Application No. 4-RRO to the supervisory authority where the RRO is registered. The application must be accompanied by the registration certificate in Form No. 3-RRO. For a stolen device, also provide a copy of the relevant document from the police.

Before filing, verify the fiscal number and device details against the certificate, identify the ground for deregistration, and choose how to receive the result. Paragraph 3 of Chapter 4 provides for Certificate No. 6-RRO to be received by post or in person from the supervisory authority, for a copy to be received by email, or for it to be obtained in the Electronic Cabinet.

Documents may be submitted on paper or electronically, subject to identification requirements. For an in-person visit, you need an identity document; a representative must also provide proof of authority. Practical recommendation: after electronic filing, retain the acknowledgments and check how the application and attachments were processed.

3. Track the deadline and obtain No. 6-RRO

Paragraph 4 of Chapter 4 of Section II sets a deadline of five calendar days from the day the application and registration certificate are received, provided the tax authority has the sealing certificate marked to confirm seal removal that was sent by the service center. Submitting only No. 4-RRO without the other required documents does not satisfy these conditions.

The tax authority enters the registration record in its information and telecommunications system and issues or sends Certificate No. 6-RRO. A copy of the certificate is placed in the Electronic Cabinet. Check its fiscal number and deregistration date, and retain the certificate with the procedure records.

If there is no result, it is practical to check whether the application was accepted, the certificate was received, and the service center’s certificate arrived. In your inquiry to the tax authority, provide the filing details and fiscal number. The procedure and deadline are set out in paragraphs 3, 4, and 7 of Chapter 4 of Section II of the Procedure for Registration and Use of RROs.

You can also check the device’s status in the data that the State Tax Service publishes daily on its website under paragraph 19 of Chapter 2 of Section II. For deregistered RROs, the data includes the fiscal number, date, reason, and ground for deregistration. Retain Certificate No. 6-RRO as proof of the procedure’s result.

How the tax authority compulsorily deregisters an RRO

The deadline depends on the ground. A separate rule applies when the service life or legally specified operating period has expired.

The decision is made using Form No. 5-RRO. It is signed by the head of the supervisory authority where the device is registered or an authorized person. Certificate No. 6-RRO confirms to the business entity that the RRO has been deregistered.

Under paragraph 4 of Chapter 4, after deciding on compulsory deregistration, the tax authority enters the deregistration record and issues or sends Certificate No. 6-RRO within five calendar days. For grounds 2 and 3, the special deadline in paragraph 6 must be applied: no later than two working days after the date on which the device must be withdrawn from service. After deregistration by tax authority decision, an electronic copy of the certificate is sent to the service center that maintained the device. The service center removes the seal for compulsory deregistration where possible.

Practical recommendation: after receiving notice that the device’s service life is ending, set the date of the last shift and prepare a replacement. The time taken by the tax authority to issue documents does not extend the RRO’s permitted operating period. These rules are set out in paragraphs 2–6 of Chapter 4 of Section II of the Procedure for Registration and Use of RROs.

What to do if the RRO is stolen, damaged, or inaccessible

If the device is stolen, contact the police and submit No. 4-RRO with a copy of the relevant police document. Paragraph 3 of Chapter 4 expressly requires this. Practical recommendation: in your inquiry to the tax authority, describe why the device is unavailable and cannot be handed to the service center. A free-form explanation does not replace the police document.

If the RRO is faulty or its seals are damaged, notify the service center during the working day on which you discover this, and notify the supervisory authority where you are registered as a taxpayer within two working days after the day of discovery. The notice may be submitted in writing or through electronic communications in any form. This duty is established by paragraph 16 of Article 3 of Law No. 265/95-VR.

A malfunction is not in itself a separate ground listed in Chapter 4. If you decide to stop using the device permanently, you may apply under subparagraph 1. Before doing so, determine with the service center which final operations are technically possible.

To continue settlements during repairs, Article 5 of Law No. 265/95-VR provides for a registered backup RRO or the use of a КОРО and РК in accordance with the prescribed rules. For a temporary power outage, this provision sets a limit of seven working days. If you have chosen to stop settlements during a malfunction or power outage without using a КОРО and РК, follow that decision until a backup device is properly connected or power is restored.

If only the registration certificate is lost, paragraph 2 of Chapter 3 of Section II of the Procedure provides for re-registration and issuance of a new certificate. Submit Application No. 1-RRO marked “Перереєстрація” (“Re-registration”), state the reason, and do so within five working days following the day of the loss.

If the device has been destroyed, lost, or left in an inaccessible area, a practical recommendation is to gather available evidence of the event, identify the RRO, and describe the circumstances in writing to the tax authority and service center. Specify which actions cannot be completed: obtaining the certificate, generating a report, transmitting data, or removing the seal. Contact the supervisory authority where the device is registered about applying the procedure to your situation.

Chapter 4 of the Procedure for Registration and Use of RROs does not establish a general substitute for seal removal in voluntary deregistration. Martial law or an inaccessible area is not listed in that chapter as a separate ground for deregistration. The special rules for lost source documents described below also do not deregister the device.

How to close a retail outlet and account for Form No. 20-ОПП

If a store closes or an object’s status changes, submit a statement of taxable objects using Form No. 20-ОПП with updated information to the tax authority where you are primarily registered. Paragraphs 8.4 and 8.5 of Section VIII of the Procedure for Taxpayer Registration, approved by Order No. 1588 of the Ministry of Finance of Ukraine dated 9 December 2011, set a 10-working-day deadline for such changes.

Information that a business unit is closed or no longer operated is a ground for deregistering a hardware RRO under subparagraph 13 of paragraph 1 of Chapter 4. For a software RRO (ПРРО), the corresponding information triggers automatic deregistration by the fiscal server. A practical step before filing No. 20-ОПП is to check all cash registers registered to that outlet and complete the transmission of their documents, if possible.

Illustrative example. An individual entrepreneur is closing one store and plans to use its device at another. A practical recommendation is to arrange in advance for the RRO to be re-registered to the new business unit and check its registration details, while meeting the deadline for reporting the previous outlet’s closure. If the closure is reported while the RRO is still registered to the old store, this will create a ground for deregistration.

Deregistering one device does not mean the store is closing. If the business unit continues operating with another RRO or software RRO (ПРРО), the information in No. 20-ОПП must reflect its actual status. You can review object information in the private section of the Electronic Cabinet under paragraph 8.8 of the Procedure for Taxpayer Registration No. 1588.

How to close out books of settlement transactions and settlement books

Registration of a КОРО for an RRO is canceled at the same time as the device is deregistered. This is provided for by paragraph 1 of Chapter 3 of Section II of the Procedure for Registration and Maintenance of РК and КОРО, approved by Order No. 547. That provision does not require a separate Application No. 2-КОРО for this simultaneous cancellation. Under paragraph 9 of Chapter 1 of Section III, the corresponding РК is also canceled when registration of the КОРО is canceled.

If the tax authority decides to cancel registration of a КОРО for an RRO, an official must enter the relevant data into the tax service’s information and telecommunications system no later than the next working day after the grounds arise. If the book is available, the official records the cancellation on its title page and certifies it with a signature and seal.

Separate Application No. 2-КОРО is used to cancel registration of the book itself, including because it has been lost, stolen, or become unusable. If you are giving up the book because you have decided to stop settlements during an RRO malfunction or power outage until a backup device is properly connected or power is restored, first record that decision in an internal directive.

Under paragraph 3 of Chapter 3 of Section II, submit Application No. 2-КОРО where the book is registered no later than two working days after the ground arises. If the book was stolen, attach a copy of the relevant police document. The tax authority cancels registration no later than the next working day after receiving the application.

A КОРО registered to a separate business unit for settlement transactions permitted by law without an RRO has its own grounds for cancellation. In particular, notification that the business unit is closed or no longer used is a ground under subparagraph 6 of paragraph 2 of Chapter 3 of Section II. When closing a store, check whether each book is registered to a particular device or to the business unit.

Practical recommendation: make a list of the numbers of all related КОРО and РК and check that their registration has been closed out. When use of a КОРО ends, enter the end date on its title page as provided by paragraph 11 of Chapter 4 of Section II. If the entity has no accounting department, that paragraph requires reports documenting cash disbursements and cancellation of incorrect transaction amounts to be attached to the last page of the book.

If all receipts in an РК have been used, enter the end date and the total amount settled using all receipts on its registration page. If an РК is lost, notify the supervisory authority where the КОРО is registered no later than two working days after the loss. These requirements are in paragraphs 9 and 10 of Chapter 2 of Section III of the Procedure for Registration and Maintenance of РК and КОРО.

Which documents and data to retain after deregistration

Until the device stops operating at the place of settlement, the registration certificate and latest sealing certificate, or copies of them, must be kept there. This is required by paragraph 4 of Section III of the Procedure for Registration and Use of RROs. After deregistration, a practical step is to assemble a separate file containing copies of submitted documents, acknowledgments, Certificate No. 6-RRO, service records, and a list of where electronic data is kept.

Expiry of the three-year periods shown in the table does not always mean the documents may be destroyed. If control tapes, КОРО, РК, or these reports substantiate tax return figures or compliance with legal requirements, also apply the relevant minimum period under paragraph 44.3 of the Tax Code of Ukraine. Retain documents connected to an audit, appeal, or court proceedings in accordance with paragraph 44.4. Before destroying any records, determine the longest applicable period for each category.

How to determine the retention period for Z-reports and other documents

For daily Z-reports, paragraph 6 of Chapter 4 of Section II of the Procedure for Registration and Maintenance of РК and КОРО refers to paragraph 44.3 of Article 44 of the Tax Code of Ukraine. The Code sets minimum periods for different document categories:

• 1825 days—for source documents, accounting records, financial statements, and other documents required by law and related to tax calculation and payment, prepared by persons specified in subparagraph 44.3.2. These include, in particular, legal entities on the general and simplified tax systems.
• 1095 days—for other documents not covered by subparagraphs 44.3.1 and 44.3.2, and for documents relating to compliance with other legislation monitored by tax authorities. For ordinary individual entrepreneur documents that are not within a special category with a longer period, apply the corresponding 1095-day rule.
• 2555 days—for documents and information required for tax control under Articles 39 and 39-2 and paragraph 141.4 of Article 141 of the Code. This special period does not automatically apply to every store document.

For Z-reports used to prepare tax returns, the period runs from the date the return is filed. If it is not filed, the period runs from the statutory filing deadline. For documents concerning compliance with other legislation, the period begins on the date of the relevant business transaction; for permits, it begins when their validity ends. The date of RRO deregistration is not, by itself, the general starting date for report retention.

Which earlier documents are subject to 1825 days

Law of Ukraine No. 2970-IX of 20 March 2023 introduced new requirements for the minimum retention period of 1825 days. The relevant amendments took effect on 28 April 2023: paragraph 1 of Section II provides that they take effect the day after publication, and the Law was published on 27 April 2023.

Paragraph 4 of Section II of that Law applies the new requirements to documents that:

• were created before the Law took effect and whose retention period had not expired as of 28 April 2023;
• were created on or after 28 April 2023;
• were created by a person whose termination or liquidation procedure had begun but was not complete on the date the Law took effect;
• were created by a person whose liquidation was decided after the Law took effect.

Accordingly, for documents of a legal entity relating to earlier periods, first determine whether their retention period had expired by 28 April 2023. Account for all applicable extensions and suspensions. If the period was still running then and the document falls within subparagraph 44.3.2, apply the 1825-day minimum. Count from the filing of the relevant tax return or another starting event under paragraph 44.3; the Law’s effective date does not restart the clock for all documents. The transitional rule does not automatically move ordinary individual entrepreneur documents into the five-year minimum category.

The grounds are set out in subparagraph 3 of paragraph 7 of Section I and paragraphs 1 and 4 of Section II of Law No. 2970-IX.

When the retention period is extended

Paragraph 44.3 extends retention periods for any period during which the statute of limitations is suspended under paragraph 102.3. That provision covers a taxpayer’s continuous presence outside Ukraine for at least 183 days; a statutory or court prohibition on conducting an audit; suspension, extension, or rescheduling of an audit in the prescribed manner; specified cases under the Code where an audit is impossible, access is denied, or an audit decision is appealed; and administrative or court appeals against an assessed monetary obligation. For a finding that an audit is impossible and an appealed audit decision, the exceptions under subparagraph 102.3.4 concerning the illegality of the relevant actions or decision must be taken into account.

Temporary provisions must also be considered for documents from earlier periods. Paragraph 52-2 of Subsection 10 of Section XX of the Code provided for the statute of limitations to be suspended from 18 March 2020 during the quarantine period defined there; paragraph 2 of Section II of Law No. 2120-IX suspended the operation of that paragraph for the period of martial law or a state of emergency.

Subparagraph 69.9 of paragraph 69 of that subsection provides for a temporary suspension of time limits until 1 August 2023, subject to listed exceptions. Therefore, the destruction date for older records cannot be determined simply by adding the basic 1095 or 1825 days. Periods when multiple grounds for suspension were in effect at the same time should not automatically be counted more than once.

If documents relate to the subject of an audit, an administrative appeal of its results, or court proceedings, paragraph 44.4 requires them to be retained until the relevant procedures and statutory appeal period have ended, but at least for the period under paragraph 44.3. A separate 1095-day extension applies to documents substantiating circumstances reported by the tax authority under paragraph 86.14 concerning possible transactions intended to provide an improper benefit to a foreign public official.

Practical recommendation: for each reporting period, record the document category, when the period starts, and any circumstances that affect its duration. For documents from earlier periods, separately check whether the transitional rule in Law No. 2970-IX and the temporary suspension of time limits apply. Retain the documents until that calculation is complete.

Reports may be retained on paper and/or electronically in a form that allows them to be viewed, including during an audit. Their data must match the electronic copies in the RRO’s fiscal memory and/or on the fiscal server. Practical recommendation: before transferring or disposing of the device, check with the service center how to preserve access to the control tape and reports. Open the saved files and check that their details are readable. Copies in accounting software cannot automatically be treated as properly retained control tapes.

Retention rules are set out in paragraphs 6, 11, and 14 of Chapter 4 of Section II and paragraph 11 of Chapter 2 of Section III of the Procedure for РК and КОРО; minimum periods, their starting points, and extensions are set out in paragraphs 44.3 and 44.4 of Article 44, paragraph 102.3 of Article 102, paragraph 52-2, and subparagraph 69.9 of paragraph 69 of Subsection 10 of Section XX of the Tax Code of Ukraine. These provisions do not set a single three-year retention period for all accounting documents, registration records, or software logs.

If the RRO is deregistered because the taxpayer is being liquidated, paragraph 44.3 of the Code also requires documents listed in paragraph 44.1 covering at least 1825 days of activity before liquidation to be transferred to the archive as prescribed by law. For documents and information required for tax control under Articles 39 and 39-2 and paragraph 141.4 of Article 141, that period is at least 2555 days.

What to do if documents are lost or damaged

The general rule in paragraph 44.5 of the Code provides that, if documents listed in paragraphs 44.1 and 44.3 are lost, damaged, or destroyed early, you must notify the supervisory authority where you are registered in writing within five days of the event. Submit the notice in the manner used for tax returns and include documents confirming the event, prepared in accordance with the law. If customs clearance documents, authorizations, or special simplifications are affected, also account for the notice to the relevant customs authority required by this paragraph.

Under the general procedure, lost documents must be restored within 90 calendar days from the day following receipt of the notice by the supervisory authority. If the loss makes an audit impossible and notice was properly and timely submitted, the relevant audit deadlines are postponed under paragraph 44.5 by no more than 120 days; an exception applies to audits under Article 200. If the documents are not restored, or are lost, damaged, or destroyed early again after the restoration procedure has been used, they are deemed absent when the relevant return is prepared or legal requirements are fulfilled.

For a lost КОРО or РК, also observe the special two-working-day deadlines described above. Practical recommendation: in your notice, list missing equipment separately from missing documents because different procedures apply to them.

How to handle source documents in active combat zones or temporarily occupied territories

Subparagraph 69.28 of paragraph 69 of Subsection 10 of Section XX of the Code sets special rules as an exception to Article 44 for taxpayers and tax agents that carried out activities in active combat zones or temporarily occupied territories of Ukraine and cannot produce source documents. The loss must be connected with hostilities. Another ground applies where documents remained in territories specified by the provision and cannot be removed, removal would endanger life or health, or administrative restrictions imposed by public authorities prevent their removal.

In such a situation, notify the tax authority in any form that the source documents cannot be removed. State the circumstances of the loss and/or inability to remove them, the tax periods, and the general list of documents; provide identifying details where possible. For an enterprise, the provision expressly requires the signatures of the manager and chief accountant. Practical recommendation for an individual entrepreneur: describe your circumstances and the list of documents in a signed request and obtain a response on whether this special procedure applies to you.

When subparagraph 69.28 properly applies, the absence of source documents alone is not grounds for challenging the return figures for the periods specified in the notice. The provision also preserves the expenses, negative values, and value-added tax (VAT) credit it specifies. After a notice that documents cannot be removed because they remain in the relevant territories, a moratorium applies to documentary audits for the specified periods.

If you learn after submitting such a notice that documents have been lost, submit a notice of loss describing the circumstances. Taxpayers who have submitted a loss notice under this provision are not subject to audit for the specified periods, including after martial law ends. For periods covered by the notice, subparagraph 69.28 prohibits upward revisions to declared tax liabilities, a negative corporate income tax base, and a claimed VAT refund.

The tax authority must prove that there are no grounds to apply these special rules. If it refuses, it must issue a reasoned decision setting out the grounds and evidence no later than one month after receiving the notice. The decision may be appealed administratively or in court. Until a final decision in the case, the restrictions under subparagraph 69.28 concerning challenges to return figures and the initiation of audits for the relevant periods remain in force. Unjustified reliance on this subparagraph entails the liability prescribed by law.

The special rules concern substantiating tax return figures with source documents. They cannot automatically be applied to any lost file, registration certificate, or RRO itself. Nor do they replace Application No. 4-RRO and Certificate No. 6-RRO. The grounds and consequences are set out in subparagraph 69.28 of paragraph 69 of Subsection 10 of Section XX of the Tax Code of Ukraine.

How to switch from a hardware RRO to a software RRO (ПРРО)

If you stop using a device whose service life has not yet expired because you are switching to a software RRO (ПРРО), its registration must be canceled and the required reporting documents submitted. This obligation is established by paragraph 10 of Section II, “Final Provisions,” of Law No. 265/95-VR and paragraph 8 of Chapter 4 of Section II of the Procedure for Registration and Use of RROs.

Practical recommendation: prepare the replacement first. Check that the software RRO (ПРРО) is registered to the required business unit, that electronic signature or seal certificate details have been entered in the register, and that the relevant certificates are valid. Then set the device’s last shift, complete reporting operations, and arrange for seal removal. Conduct subsequent transactions through the prepared registered device.

If you plan to keep the hardware device as a backup, check its registration status and the list of business units in its certificate. A backup must be a duly registered RRO; the certificate has a “Резервний” (“Backup”) mark, a storage location, and the business units where it may be used. You must notify the tax authority in advance that those units are taxable objects. A closed fiscal number cannot be used. These rules are in paragraph 20 of Chapter 2 of Section II and paragraph 12 of Section III of the Procedure for Registration and Use of RROs.

Also account for the restriction in paragraph 1 of Article 3 of Law No. 265/95-VR: software RROs (ПРРО) may not be used for wholesale or retail trade in fuel.

How to separately deregister a software RRO (ПРРО)

Software RROs are governed by the Procedure for Registration, Maintenance of the Register, and Use of Software Cash Registers, approved by Order No. 317 of the Ministry of Finance of Ukraine dated 23 June 2020. Form No. 4-RRO and the seal removal procedure do not apply.

1. Transmit accumulated documents and close the shift. Before filing, ensure that all copies of transaction documents with numbers assigned offline, electronic fiscal reporting receipts, and notices required by the Procedure have been transmitted. Under Article 5 of Law No. 265/95-VR, copies of transaction documents created offline must be transmitted within one hour after communications are restored, and before transmitting the electronic fiscal report or fiscal reporting receipt for that day. Retain documents until the server confirms delivery.
2. Submit electronic Application No. 1-ПРРО marked “Скасування реєстрації” (“Deregistration”) through the Electronic Cabinet or by telecommunications.
3. Check the deregistration notice in the Electronic Cabinet and retain it. The notice states the ground for deregistration.

If the software RRO is faulty or stolen, or its private key has been compromised, paragraph 12 of Section II requires Notice No. 2-ПРРО to be submitted on the day the event is discovered to the supervisory authority, software RRO manufacturer, and/or service center, if applicable. Compromise means that the security of the private key has been breached. A notice marked “крадіжка пристрою чи компрометація ключа” (“device theft or key compromise”) is a ground for deregistration.

If a malfunction is reported, a corresponding note is entered in the register. Stop settlement transactions while the device is faulty until the fault is fixed or a duly registered backup hardware RRO is connected. After the fault is fixed, submit No. 1-ПРРО marked “Відновлення роботи” (“Resume operation”) to restart the software RRO. If this application is not received within a month, a deregistration entry is made in the register. Notice No. 2-ПРРО is not a required attachment to every voluntary deregistration application.

The fiscal server also automatically deregisters a software RRO in the cases listed in paragraph 3 of Section III: state registration of the entity’s termination; notice that a business unit is closed or no longer operated; court decisions specified in that provision; information about the death or relevant legal status of an individual entrepreneur; or removal of the entity from the tax register in other cases covered by the provision. The software RRO is removed from the register and its fiscal number is closed and cannot be used again. The grounds and result are governed by paragraph 12 of Section II and Section III of the Procedure for Software RROs No. 317.

How to finish working with a fiscal printer in Torgsoft

A hardware fiscal printer requires the activated paid “Інтеграція з фіскальним реєстратором” (“Integration with a fiscal printer”) option, a supported model, and a configured driver. “Вилучення готівки” (“Cash withdrawal”) and “Друк Z-звіту” (“Print Z-report”) are available under “Документ → Реалізація → Фіскальний реєстратор” (“Document → Sale → Fiscal printer”). Settings depend on the equipment; check the integration instructions. Practical recommendation: check that final operations are complete before handing the device to the service center.

To reconcile, generate the “Касові операції” (“Cash operations”) report in “Фінансовому документі” (“Financial document”), setting the till, currency, and both dates for the period. The report can be printed or exported to Excel; deletion of a financial document is recorded in “Протокол дій користувачів” (“User actions log”): financial documents help. Practical recommendation: save the report for checking balances.

“Програмний РРО” (“Software RRO”) is also a paid option. It must be activated at the workstations and configured under “Налаштування → Програмний РРО” (“Settings → Software RRO”). The “Не діє” (“Inactive”) status blocks transactions and actions; editing offline is prohibited. The “Надрукувати Z-звіт” (“Print Z-report”) action is for administrators: software RRO help. Practical recommendation: before changing the status, check that documents have been delivered and the shift has been closed. Both options are billed annually, separately for each device; check current prices and terms before payment. Deregistration with the tax authority is completed separately.

What liability applies to transactions after deregistration

Paragraph 1 of Article 3 of Law No. 265/95-VR requires transactions for which an RRO or software RRO (ПРРО) is mandatory to be processed through a registered, properly sealed device in fiscal mode, or through a registered software RRO. After deregistration, the device cannot be used to meet this requirement.

If an audit establishes that transactions were not processed through a fiscal-mode RRO or software RRO, or that the required transaction document was not issued, paragraph 1 of Article 17 provides for a penalty of 100% of the amount of the sale made in violation for the first violation and 150% for each subsequent violation. Liability depends on the specific breach of settlement rules established. Keeping a switched-off device after deregistration is not a violation described in this paragraph.

Paragraph 14 of Section II, “Final Provisions,” provides territorial exemption from liability for violations committed from 1 October 2023 while selling goods or providing services in temporarily occupied territories and areas of active or possible hostilities. It applies until the relevant dates for the end of occupation, hostilities, or the possibility of hostilities under the official list of territories, and does not cover settlement procedure violations involving excisable goods. To apply the exemption, establish the status of the particular territory and the transaction date.

The reduced penalties of 25% and 50% under paragraph 15 for specified individual entrepreneurs applied from 1 August 2023 through 31 July 2025, but no later than the end or cancellation of martial law. These rates do not apply to transactions after 31 July 2025. Deregistration also does not automatically invalidate receipts properly generated before deregistration. Liability is assessed based on the particular transaction and the conditions in Article 17 and paragraphs 14 and 15 of Section II of Law No. 265/95-VR.

Official legal sources

• Law of Ukraine “On the Use of Cash Registers in Trade, Public Catering and Services” dated 6 July 1995 No. 265/95-VR: Article 2; paragraphs 1, 2, 6, 7, 9, 10, and 16 of Article 3; Article 5; paragraph 1 of Article 17; paragraphs 10, 14, and 15 of Section II, “Final Provisions.”
• Order No. 547 of the Ministry of Finance of Ukraine “On Approval of Procedures for Registration of Cash Registers and Books of Settlement Transactions” dated 14 June 2016; the approved Procedure for Registration and Use of Cash Registers for Registering Settlements for Goods (Services): paragraph 1 of Section I; paragraph 3 of Chapter 1, paragraphs 19 and 20 of Chapter 2, Chapters 3 and 4 of Section II; paragraphs 2–6, 8, 10, and 12 of Section III; Appendices 1 and 3–6.
• Procedure for Registration and Maintenance of Settlement Books and Books of Settlement Transactions, approved by Order No. 547 of the Ministry of Finance of Ukraine dated 14 June 2016, registered under No. 920/29050: Chapter 2, paragraphs 1–3 of Chapter 3, paragraphs 6, 11, and 14 of Chapter 4 of Section II; paragraphs 8 and 9 of Chapter 1, paragraphs 9–11 of Chapter 2 of Section III; Appendices 3 and 4.
• Order No. 317 of the Ministry of Finance of Ukraine “On Amendments to Order No. 547 of the Ministry of Finance of Ukraine dated 14 June 2016” dated 23 June 2020; the approved Procedure for Registration, Maintenance of the Register, and Use of Software Cash Registers: paragraphs 3, 7, and 12 of Section II; Section III; paragraphs 1, 2, and 5 of Section IV; paragraphs 4 and 8 of Section V; Appendices 1, 2, and 5.
• Order No. 1588 of the Ministry of Finance of Ukraine “On Approval of the Procedure for Taxpayer Registration” dated 9 December 2011; the approved Procedure for Taxpayer Registration: paragraphs 8.1, 8.4, 8.5, and 8.8 of Section VIII; Appendix 10—Form No. 20-ОПП.
• Tax Code of Ukraine dated 2 December 2010 No. 2755-VI: paragraphs 44.1 and 44.3–44.5 of Article 44, including subparagraphs 44.3.1–44.3.4 on minimum retention periods; paragraph 102.3 of Article 102 on suspension of the limitation period; paragraph 52-2 and subparagraphs 69.9 and 69.28 of paragraph 69 of Subsection 10 of Section XX on temporary deadlines and special rules for source documents.
• Law of Ukraine “On Amendments to the Tax Code of Ukraine and Other Legislative Acts of Ukraine Regarding the Operation of Provisions During Martial Law” dated 15 March 2022 No. 2120-IX: paragraph 2 of Section II on suspension of paragraph 52-2 of Subsection 10 of Section XX of the Tax Code of Ukraine.
• Law of Ukraine “On Amendments to the Tax Code of Ukraine and Other Legislative Acts of Ukraine to Implement the International Standard for Automatic Exchange of Financial Account Information” dated 20 March 2023 No. 2970-IX: subparagraph 3 of paragraph 7 of Section I—amendments to paragraph 44.3 of the Tax Code of Ukraine; paragraphs 1 and 4 of Section II—entry into force and application of the new 1825-day minimum retention requirement to previously created documents and documents of persons undergoing termination or liquidation.