Cash Withdrawal and Cash Deposit Operations in ECR/PECR: When to Perform Them, What to Do If You Forget, and What Penalties Apply

The «cash withdrawal» operation does not need to be performed automatically at the end of every cash register shift. It is required when cash is physically removed from the place of settlement and the removal is not a settlement transaction with a customer. If the money remains at the place of settlement after the Z-report, the State Tax Service explicitly permits not performing a cash withdrawal at the end of the day: before the first settlement transaction on the following working day, the remaining cash must be registered through the ECR/PECR as a «cash deposit».

Law No. 265 does not establish a penalty of 100% or 150% of the cash amount or sale amount merely for failing to perform a cash withdrawal. Such penalties are provided for in paragraph 1 of Article 17 of Law No. 265 for other specific violations: processing a settlement for less than the full amount, failing to process a settlement transaction through a fiscal ECR/PECR, and failing to issue a proper settlement document. A separate penalty for discrepancies between actual cash and the daily report data was abolished by Law No. 1017-IX.

What Are «Cash Withdrawal» and «Cash Deposit» Operations?

Regulations use the term «cash withdrawal». In software and everyday cashier operations, the same action is often referred to as «removing cash» or «cash collection».

The procedures governing ECR and PECR use define two separate operations:

• «cash deposit» — registering cash present at the place of settlement before the first settlement transaction following a Z-report;

• «cash withdrawal» — registering the amount of cash removed from the place of settlement and/or issued to holders of electronic payment instruments in cases provided for by law.

These operations are used when depositing or withdrawing cash is not related to a settlement transaction with a customer. «Cash deposit» and «cash withdrawal» are not themselves settlement transactions within the meaning of Law No. 265.

This is an important distinction. Selling goods, receiving payment, or refunding a customer for returned goods are subject to their own fiscalization rules. An ordinary «cash withdrawal» cannot replace the proper registration of a sale or customer refund.

When Is a Cash Withdrawal Required?

A cash withdrawal is performed when cash physically leaves the place of settlement and its disbursement is not a settlement with a customer.

Typical situations:

The need for a cash withdrawal is determined by the actual movement of cash, not by the formal end of a shift.

Is a Cash Withdrawal Required Before Every Z-Report?

No. Legislation does not require a cashier to reduce the cash balance to zero through a cash withdrawal before every Z-report.

The State Tax Service specifically addresses situations where cash remains at the place of settlement after a Z-report. If that amount is registered through the ECR or PECR as a «cash deposit» before the first settlement transaction on the next working day, there is no need to perform a cash withdrawal at the end of the previous day.

Therefore, there are two normal scenarios:

1. Money is removed from the place of settlement before the end of work. The physical removal must be registered as a «cash withdrawal».

2. Money remains at the place of settlement. A separate cash withdrawal solely for the Z-report is unnecessary; the balance is recorded through a «cash deposit» before the first settlement transaction after the Z-report.

For conventional ECRs, the State Tax Service additionally explains that cash disbursements unrelated to settlements are not processed through the ECR if they occur after the Z-report but before the next settlement transaction and/or before the «cash deposit» operation.

What to Do If a Cashier Generated a Z-Report and Forgot the Cash Withdrawal

If the money was not physically removed and remained at the place of settlement after the Z-report, there is no need to separately «correct» the previous shift.

Before the first settlement transaction on the next working day, register a «cash deposit» through the ECR/PECR for the amount of cash remaining at the place of settlement. This procedure is explicitly described by the State Tax Service in its current clarification.

Example

A store closes its shift and generates a Z-report. UAH 4,000 in cash remains at the cash register location and has not been removed. The cashier should not artificially register an operation for the previous period after the shift has closed. Before the first settlement transaction on the following working day, UAH 4,000 is registered as a «cash deposit». According to the State Tax Service, a cash withdrawal at the end of the previous day is not required in this scenario.

However, if the money was physically removed from the place of settlement at a time when the removal should have been registered, the situation is different: fiscal operations must not be created retroactively with inaccurate dates or amounts. Further actions must reflect the actual movement of funds and the company's records.

Is an Internal Memo or Accounting Statement Required?

Law No. 265 and the procedures for using ECR/PECR do not impose a separate obligation to prepare an internal memo, explanatory note, or accounting statement solely because a cash withdrawal was not performed at the end of the day.

A company may use such internal documents for its own controls, particularly if a cashier has violated internal procedures or if cash movements need to be explained to the accounting department. However, an internal memo does not itself change fiscal server data and does not replace a properly registered ECR/PECR operation.

Legal entities are also subject to the rules for documenting cash transactions under NBU Regulation No. 148. Therefore, transferring money from a retail location to the company's cash office or depositing it at a bank may require cash and bank documents regardless of the fiscal «cash withdrawal» operation.

Depositing Revenue at a Bank: Cash Withdrawal and Supporting Documents

If cash is removed from the place of settlement for deposit at a bank, NBU Regulation No. 148 and State Tax Service clarifications require such removal to be recorded as a «cash withdrawal».

Depending on how the money is deposited, proof of depositing revenue at a bank may include:

• a receipt attached to the bank's cash receipt document;

• an ATM or self-service terminal receipt;

• an accompanying cash order for a valuables bag;

• a payment terminal receipt for real-time cash collection.

For a company, disbursing cash from its cash office for deposit at a bank must also be documented with the appropriate cash documents and recorded in the cash book in accordance with Regulation No. 148.

Therefore, a «cash withdrawal» through an ECR/PECR and the accounting documentation of cash movements are not the same document. The first records the movement of funds at the fiscal level, while cash or bank documents confirm the subsequent actual movement of money in business operations.

Can Revenue Remain at the Cash Register Location After a Shift Closes?

Generating a Z-report does not in itself mean that all cash must be physically removed from the retail location. The State Tax Service permits cash to remain at the place of settlement, provided a subsequent «cash deposit» is performed before the first settlement transaction after the Z-report.

If the cash drawer cannot physically hold all the revenue, the State Tax Service also permits keeping some money in a safe, provided the safe is located at the actual place of settlement and contains only revenue from sales processed using the corresponding ECR/PECR.

Companies must also separately comply with cash balance limits and revenue deposit deadlines established by NBU Regulation No. 148.

Cash Balance Limits for Sole Proprietorship Owners and Legal Entities

The rules for Sole Proprietorship owners differ from those for companies. According to State Tax Service clarifications under NBU Regulation No. 148, individual entrepreneurs are entitled not to establish a cash balance limit or deadlines for depositing cash revenue and are not required to maintain a cash book.

However, this does not eliminate the rules governing ECR/PECR operations. If a Sole Proprietorship owner uses an ECR/PECR and physically deposits or removes cash at the place of settlement outside a customer settlement transaction, the rules on «cash deposit» and «cash withdrawal» apply.

For companies, Regulation No. 148 establishes cash management requirements, including setting a cash balance limit, revenue deposit deadlines, and documenting the relevant cash transactions. Therefore, monitoring only ECR/PECR operations is not sufficient for a legal entity — cash movements must also be reconciled with its accounting records.

What Is the Penalty for a Missed Cash Withdrawal?

The current Article 17 of Law No. 265 does not establish a separate financial penalty specifically described as a fine for «failure to perform a cash withdrawal».

Paragraph 1 of Article 17 provides for the following:

These penalties apply specifically to the violations listed in paragraph 1 of Article 17. Therefore, it is incorrect to automatically treat a forgotten cash withdrawal, which is not a settlement transaction, as an unregistered sale and calculate a penalty of 100% or 150% of the remaining cash balance.

Previously, Law No. 265 contained requirements and penalties relating to discrepancies between cash at the place of settlement and the amount shown in the ECR daily report. Law No. 1017-IX abolished the relevant financial penalties. Therefore, claims that a separate penalty still applies merely because of a discrepancy between cash and the Z-report under the old rules do not reflect current regulations.

At the same time, the absence of a separate percentage-based penalty does not mean that cash operations can be disregarded. Procedures No. 547 and No. 317 expressly require cash deposits and withdrawals at the place of settlement unrelated to settlement transactions to be registered through the ECR/PECR.

Is a Z-Report Required If There Were Only Cash Deposit or Withdrawal Operations?

If there were no settlement transactions during the day and only «cash deposit» and/or «cash withdrawal» operations were performed, generating a Z-report solely because of these operations is unnecessary.

The reason is that Law No. 265 links the requirement to generate a fiscal daily report specifically to settlement transactions, whereas cash deposits and withdrawals are not settlement transactions. This is expressly confirmed by the current clarification in the State Tax Service's public information resource.

How to Correct an Incorrect Cash Withdrawal or Deposit in a PECR

A different situation arises when the cashier has not forgotten an operation but has performed it incorrectly.

For PECR, the State Tax Service establishes the following procedure:

The correction is also registered on the fiscal server.

For conventional ECRs, the rules depend on the nature of the error and the technical capabilities of the particular register. In particular, the State Tax Service states that an incorrect «cash deposit» in an ECR can be corrected before the end of the working day using a negative amount or a «cash withdrawal», but legislation does not provide a mechanism for making this correction through the ECR on the following day.

Cash Deposits, Cash Withdrawals, and Revenue Transfers in Torgsoft PECR

Torgsoft's PECR functionality provides separate fiscal actions for cashiers. The software ECR menu includes opening a shift, generating X-reports and Z-reports, depositing money into the cash register, and withdrawing money from it. This means a cashier can perform the required «cash deposit» or «cash withdrawal» directly while working with the PECR in the software.

Torgsoft also provides a separate revenue transfer function as a management accounting operation. The salesperson specifies the amount, the cash register from which the money is transferred, and the receiving cash register. The software shows the cash register balance and, after saving, creates two financial documents: an expense document for the salesperson's cash register and a receipt document for the receiving cash register. This operation represents an internal transfer of business funds and must not be confused with a fiscal «cash withdrawal»: if revenue is physically removed from the place of settlement during the transfer, the cashier must also comply with ECR/PECR requirements.

For incorrectly registered fiscal documents, Torgsoft provides a storno function: in the software ECR section, you can open receipt operations and select «Receipt Storno». Torgsoft's help documentation explicitly states that storno can be used, among other things, after an incorrect cash deposit or withdrawal; the corresponding document is transmitted to the fiscal server and receives a fiscal number. This function must be used in accordance with the State Tax Service rules for correcting the specific operation.

Quick Checklist for Cashiers

1. At the start of work, check whether any cash remains at the place of settlement after the previous Z-report or has been added to provide change. Before the first settlement transaction, register the corresponding amount as a «cash deposit».

2. If cash is physically removed from the place of settlement during a shift for reasons unrelated to a customer settlement, register a «cash withdrawal».

3. Do not automatically perform a cash withdrawal merely because the working day is ending. If the money remains at the place of settlement, register it as a «cash deposit» before the first settlement transaction on the following working day.

4. If revenue is deposited at a bank, prepare not only the cash withdrawal operation but also the appropriate bank document; for companies, prepare the cash documents required by Regulation No. 148 as well.

5. Do not use a cash withdrawal as a substitute for a customer refund receipt or another settlement transaction.

6. If a cash operation was incorrectly performed through a PECR, correct it using the method specified by the State Tax Service: a reverse operation or storno, depending on the type of error.

Official Sources

1. Law of Ukraine «On the Use of Registrars of Settlement Transactions in Trade, Catering and Services» dated July 6, 1995, No. 265/95-VR — Article 2 defines settlement transactions; Article 3 establishes the main ECR/PECR obligations; Article 17 establishes financial penalties for incomplete fiscalization, failure to register a settlement transaction, and failure to issue a receipt.
   https://zakon.rada.gov.ua/laws/show/265/95-%D0%B2%D1%80

2. Order of the Ministry of Finance of Ukraine dated June 14, 2016, No. 547, «On Approval of Procedures for Registering Registrars of Settlement Transactions and Books of Settlement Transactions» — paragraph 6 of Section III of the ECR Use Procedure governs «cash deposits» and «cash withdrawals».
   https://zakon.rada.gov.ua/laws/show/z0918-16

3. Order of the Ministry of Finance of Ukraine dated June 23, 2020, No. 317, «On Amendments to Order No. 547 of the Ministry of Finance of Ukraine dated June 14, 2016» — approved, among other things, the procedure for registering and using software ECRs; paragraph 9 of Section IV of the relevant Procedure applies to cash operations.
   https://zakon.rada.gov.ua/laws/show/z0635-20

4. Resolution of the Board of the National Bank of Ukraine dated December 29, 2017, No. 148, «On Approval of the Regulation on Conducting Cash Transactions in the National Currency in Ukraine» — including provisions on recording cash receipts, depositing revenue, cash documents, and cash balance limits. The document remains in force.
   https://zakon.rada.gov.ua/laws/show/v0148500-17

5. Law of Ukraine dated December 1, 2020, No. 1017-IX — among other changes, abolished financial penalties for discrepancies between cash at the place of settlement and the amount stated in the ECR daily report.
   https://zakon.rada.gov.ua/laws/show/1017-20

6. State Tax Service Public Information Resource: «Must a Business Perform a Cash Withdrawal Operation Through an ECR or PECR at the End of the Working Day?» — official clarification permitting cash to remain after a Z-report and requiring a «cash deposit» before the next settlement transaction.
   Official State Tax Service clarification

7. State Tax Service Public Information Resource: «How Can an Incorrect Cash Withdrawal or Cash Deposit Operation Performed Through a PECR Be Canceled (Corrected)?» — procedure for reverse operations and storno.
   Official State Tax Service clarification