Cash Payments for Sole Proprietors: Limits, Documents, and Fines

In Ukraine, an individual entrepreneur (ФОП, Ukrainian abbreviation for an individual entrepreneur) may make cash payments to another entrepreneur or a business entity up to UAH 10,000 inclusive per day with one counterparty, and to an ordinary individual up to UAH 50,000 inclusive per day with one person. Before accepting or handing over money, determine the status in which the other party is acting, total the cash payments already made with them, and check whether an exception applies.

If a payment exceeds the permitted amount, arrange a transfer between accounts or deposit the money at the cash desk of a payment service provider for onward transfer to the recipient’s account. Separately check whether you must issue a fiscal receipt: complying with the cash limit and processing the transaction through a settlement transaction registrar (РРО, Ukrainian abbreviation) or software settlement transaction registrar (ПРРО, Ukrainian abbreviation) are separate requirements.

Which cash limit applies to a payment

The main rules are set out in paragraphs 6–8 of the Regulation on Cash Transactions in the National Currency of Ukraine, approved by Resolution No. 148 of the National Bank of Ukraine (NBU) dated 29 December 2017. They apply to payments in hryvnias, both for goods, works, and services and for other cash payments, unless a specific exception applies.

Source: paragraphs 3, 6, and 7 of Regulation No. 148. These provisions do not set a general UAH 50,000 limit for all payments between ordinary individuals without exception: the relevant subparagraph applies specifically to sale and purchase agreements requiring notarization.

The other party’s status in the specific transaction determines which limit applies. If the buyer purchases goods as an individual entrepreneur, the business limit of UAH 10,000 applies. If the person buys goods for personal use as a consumer, the UAH 50,000 limit applies. In practice, it is advisable to clarify this before preparing the invoice and taking payment so that the documents reflect the actual transaction.

There is no limit on the number of counterparties per day. An individual entrepreneur may pay several suppliers separately, up to UAH 10,000 with each. The shop’s total cash turnover for the day may therefore exceed UAH 10,000 or UAH 50,000.

How to calculate the daily total: receipts, advances, and refunds

Paragraph 6 of Regulation No. 148 expressly covers one or several payment documents. A new invoice, a different delivery note, a second cashier, or a separate purchase does not create a new daily limit for the same pair of parties. For monitoring purposes, total all actual cash transactions between them during the day that are subject to the limit.

If money moves in both directions during the day, do not calculate the permitted amount as the difference between receipts and payouts. Accepting payment and refunding money are separate actual transactions; Regulation No. 148 does not provide that a refund restores the portion of the cash limit already used. For practical monitoring, count both directions without offsetting them against each other. The State Tax Service of Ukraine’s clarification confirms that when a business entity accepts cash from an individual and pays cash to the same individual during one day, the total of those transactions must not exceed UAH 50,000.

Examples to check before payment

• Hypothetical supplier example. An individual entrepreneur paid another individual entrepreneur UAH 6,500 in cash and later needs to pay another UAH 4,000. The total would be UAH 10,500. The remaining cash allowance for that day is UAH 3,500: 10,000 − 6,500. The remaining UAH 500 can be transferred from account to account, with both parts of the payment properly documented.
• Hypothetical customer example. A consumer paid a shop UAH 32,000 in cash and wants to buy another UAH 19,000 worth of goods the same day. The total would be UAH 51,000. If there have been no other cash transactions that day, the shop may accept another UAH 18,000 in cash and take the remaining UAH 1,000 by cashless payment.
• Hypothetical example with different counterparties. An individual entrepreneur pays three different suppliers UAH 10,000 each in cash. The total is UAH 30,000, but the limit for each pair of counterparties is respected if there were no other relevant payments between them that day.
• Hypothetical refund example. A customer paid UAH 40,000 in cash and returns all the goods on the same day. If the shop also pays out UAH 40,000 in cash, the total cash movement between the parties is UAH 80,000. To make a full refund that day without exceeding the cash limit, arrange a properly documented cashless refund and issue the relevant settlement document.

The limits in paragraphs 6 and 7 do not mean that one purchase may never be paid in instalments over different days. If the agreement provides for actual instalments, each payment is made on its actual date, and the daily amount with that counterparty does not exceed the applicable limit, the existence of several instalments does not in itself breach the daily limit. For example, a hypothetical UAH 28,000 purchase between two individual entrepreneurs may be paid in three actual instalments on different days: UAH 10,000 + UAH 10,000 + UAH 8,000.

Agree on the payment schedule with the counterparty and record it in the documents. If all the cash was handed over today, issuing several receipts with future dates does not change the actual date of payment. For a sale and purchase between individuals requiring notarization, follow the separate rule in subparagraph 2 of paragraph 7 rather than the example above concerning daily business payments.

How to pay an amount above the cash limit

Paragraphs 6 and 7 of Regulation No. 148 provide for two main methods: transfer funds from one account to another, or deposit funds at the cash desk of a payment service provider for onward transfer to the recipient’s account. This may be a bank or an eligible non-bank provider authorized to carry out the relevant payment transaction.

1. Obtain the counterparty’s account details and a document supporting the payment, such as an agreement, invoice, or other relevant document.
2. Agree on the payment method before handing over the money. For a mixed payment, specify the cash and cashless portions separately.
3. For a deposit at a cash desk, give the provider the correct details for the payer and recipient, the account details, and the payment purpose. Follow the provider’s requirements for identification and supporting documents.
4. Keep the receipt or transfer confirmation, and verify that the funds were received against the account statement.

Depositing cash for transfer is classified differently for the two parties. Under paragraph 10 of Regulation No. 148, if a payer deposits cash at a provider’s cash desk without opening an account, for transfer to another person’s account, this is a cash payment for the payer and a cashless payment for the recipient. At the same time, paragraphs 6 and 7 expressly allow this method for payments above the limits. The basis is therefore a properly documented transfer through a cash desk to the recipient’s account, as provided for in those paragraphs.

If the seller first accepts the full amount in banknotes at its own premises and later deposits the proceeds into its own account, that does not turn the earlier payment from the buyer into a cashless transaction. Likewise, a terminal or third-party intermediary is not automatically an allowed method for paying above the limit: determine who provides the payment service and where the funds are credited.

Card payments and cash withdrawals: what to check separately

Paying with a personal payment card through a bank terminal is not the transfer of banknotes or coins. The UAH 10,000 and UAH 50,000 cash limits do not apply to such card payments. However, a card transaction may still require a fiscal receipt under Ukrainian Law No. 265/95-ВР dated 6 July 1995.

If the cardholder first withdraws money and then hands it to the seller in cash, the relevant cash limit applies. Paragraph 6 of Regulation No. 148 separately extends the restriction to cash payments for goods for production or business needs using cash obtained through a payment instrument. Therefore, an employee buying goods on behalf of an entrepreneur must take into account the status of the parties to the purchase.

Limits on withdrawing money from an account and the maximum payment to a seller regulate different transactions. Before making a large cash payment, check with the bank how much can be withdrawn, whether the cash needs to be ordered, and which documents are required. Paragraph 6 also requires a business entity, at the payment service provider’s request, to provide supporting documents if it withdraws funds for cash payments to individuals.

All exceptions to the cash limits

Paragraph 8 of Regulation No. 148 sets out five exceptions to the limits in paragraphs 6 and 7. Before relying on an exception, check the nature of the transaction and keep documents confirming that it applies.

• Payments by business entities to budgets and state targeted funds. For example, a relevant payment to the budget. Buying goods from a state-owned enterprise is not, by itself, a payment to the budget.
• Voluntary donations and charitable assistance. The documents must confirm that this is the actual basis for transferring the funds. An ordinary payment for goods or a loan does not become charitable assistance just because the payment is given a different label.
• Use of cash issued for a business trip. Keep documents confirming the business trip and relevant expenses, including travel and accommodation. Buying goods for a shop during a trip does not become a business-trip expense just because the purchase was made by an employee on a business trip: assess a business purchase under the general limits.
• Payroll-related payments. This term is defined in subparagraph 1 of paragraph 3 of Regulation No. 148 by reference to the Instruction on Statistics of Salaries, approved by Order No. 5 dated 13 January 2004. Before applying the exception, check that the specific payment falls into this category. Do not automatically treat remuneration under a civil law contract as salary.
• Use of funds from special funds of specified authorities. This refers exclusively to funds established under part three of Article 24 of the Law of Ukraine “On the National Anti-Corruption Bureau of Ukraine,” part two of Article 32 of the Law of Ukraine “On the Bureau of Economic Security of Ukraine,” and part four of Article 17 of the Law of Ukraine “On the State Bureau of Investigation.” An entrepreneur’s ordinary cash reserve is not covered by this exception.

These exceptions remove the relevant cash amount limit. They do not cancel requirements for supporting documents, tax accounting, or documenting the specific payment.

Loans, financial assistance, and adding funds to your own account

The definition of cash payments in paragraph 3 of Regulation No. 148 also covers transactions not directly related to sales. Therefore, issuing or repaying a loan or repayable financial assistance, or a founder contributing funds, is not automatically exempt from the limits. For payments between business entities, check the UAH 10,000 limit; between a business and an individual, check the UAH 50,000 limit and whether a specific exception applies.

An individual entrepreneur depositing their own cash into their business account should be distinguished from meeting an obligation to another person. Adding funds to your own account is not, in itself, a payment to another counterparty under paragraphs 6 and 7. Keep the deposit document and evidence of the source of funds; determine the tax treatment of the amount based on the actual reason for its receipt. If another participant in the transaction first handed over the money, subsequently crediting it to your own account does not remove the need to assess the earlier payment.

What documents an individual entrepreneur needs to handle cash

An individual entrepreneur is not required to keep a cash book—this is expressly provided for in paragraph 39 of Regulation No. 148. Under paragraph 14, an individual entrepreneur is also not subject to a cash balance limit or deadlines for depositing cash proceeds. Therefore, the daily limit for payments with a counterparty does not restrict the entrepreneur’s total cash balance.

However, an individual entrepreneur must properly account for income and document settlement transactions. Paragraph 11 of Regulation No. 148 sets a general rule to record the full amount of cash actually received on the day it is received, and separately defines entrepreneurs’ income accounting by reference to the Tax Code of Ukraine.

Under paragraph 296.1 of Article 296 of the Tax Code of Ukraine, individual entrepreneurs who are single tax payers in Groups 1 and 2, and those in Group 3 who are not registered as value added tax (VAT) payers, keep records in any form by recording income received each month. Group 3 payers registered for VAT use a standard form for recording income and expenses. Monthly tax accounting does not postpone the deadline for issuing a required fiscal receipt or change the actual date payment is received.

An individual entrepreneur using the general taxation system must keep records of income and expenses under paragraph 177.10 of Article 177 of the Tax Code of Ukraine and the standard form approved by Order No. 261 of the Ministry of Finance of Ukraine dated 13 May 2021. The entrepreneur records income received and expenses supported by documents on the basis of primary documents at the end of each working day on which income was received or expenses were incurred. Therefore, under the general taxation system, this daily procedure must be followed, and the entrepreneur must also have documents confirming the origin of the goods.

In practice, it is advisable to keep together the documents supporting the payment and its execution: an agreement or invoice, a delivery note or acceptance certificate, a receipt or voucher, and transfer confirmation. For a refund, add documents linking the payout to the original purchase.

If an individual entrepreneur pays a legal entity through its cash desk, the business documents receipt of the funds under its own rules. A receipt for a cash receipt order confirms that the business accepted the cash, but does not replace a fiscal receipt when the law requires the sale to be processed through an РРО or ПРРО. Sources: paragraphs 23–25 of Regulation No. 148 and Article 3 of Law No. 265/95-ВР.

When an РРО or ПРРО is required

As a general rule, under Articles 2 and 3 of Law No. 265/95-ВР, a seller processes settlement transactions for sales of goods and provision of services through a duly registered РРО or ПРРО and gives the buyer a settlement document for the full transaction amount. This applies to both cash and card payments. Where settlement transactions take place, the seller must also create a fiscal report receipt each day.

Check whether you may operate without a registrar under a specific provision:

• Group 1 single tax payers. The exemption is provided for by paragraph 296.10 of Article 296 of the Tax Code of Ukraine in conjunction with paragraph 6 of Article 9 of Law No. 265/95-ВР. Single tax payer status in Group 2 or 3 does not, by itself, provide this general exemption.
• Special cases under Article 9. The article contains separate exemptions with conditions relating to the activity, goods, and payment method. In particular, paragraph 14 concerns services paid for exclusively through remote banking systems and/or money transfer services. This provision cannot be applied to every sale of goods.
• Settlement books instead of a registrar. Article 10 provides for specific business forms and conditions under which settlement books and transaction record books are allowed. The requirements of the relevant government list must be met, including the annual transaction volume limit.

Transfers between accounts using bank details and card payments through acquiring require separate assessment. The fact that funds are credited to a seller’s account does not by itself mean that every such payment must be processed through an РРО, or that it is always exempt from one. Establish the actual payment method and check it against the definition of a settlement transaction and the relevant exceptions.

When a ПРРО is disconnected from the fiscal server, paragraph 13 of Section II, “Final Provisions,” of Law No. 265/95-ВР allows the usual offline operating time limits—36 consecutive hours and 168 hours per calendar month—to be exceeded during martial law, a state of emergency, or force majeure circumstances. A range of numbers must have been obtained from the fiscal server in advance. The settlement documents must state that the transactions were processed offline.

Under Article 5 and paragraph 16 of Article 3 of that Law, within one hour after the connection is restored, the seller must transmit to the fiscal server copies of the offline settlement documents and a notice of the time and date when those settlements began and ended. The documents must be transmitted before the fiscal report and fiscal report receipt for the relevant day are sent, and must be stored in the ПРРО until delivery is confirmed.

These rules do not change the UAH 10,000 and UAH 50,000 cash limits.

How to organize daily cash monitoring in a shop

The procedure below is a practical recommendation for monitoring payments. It helps account for transactions made by several cashiers and catch an excess before the next payment.

1. Identify the transaction participant. Establish whether the buyer is acting as a consumer, an individual entrepreneur, or a representative of a legal entity. For a business purchase, use the details of the actual counterparty.
2. Check all their payments for the day. Include earlier advances, top-up payments, other agreements, and refunds at all of the same seller’s locations. Changing the till or employee does not change the parties to the transaction.
3. Check separately whether an exception applies. If the payment falls under paragraph 8 of Regulation No. 148, keep documents confirming the basis for it.
4. Agree on an allowed payment method. Before handing over money, determine the cash portion, cashless portion, or actual instalment schedule across different days.
5. Record the actual transaction. Keep the date, amount, direction of funds, payment method, counterparty, and supporting document number. Issue a fiscal receipt if required.
6. Reconcile the data at the end of the day. Compare the cash, settlement documents, and confirmed account credits. Resolve discrepancies before the next payment with that counterparty.

You can use a simple table with these fields for monitoring. Do not require copies of every retail customer’s passport solely for this record keeping. For specific transactions, follow the applicable identification rules: for example, paragraph 27 of Regulation No. 148 requires a business, when paying out cash under a cash disbursement order or cash disbursement sheet, to check an identity document, record its details, and obtain the recipient’s signature.

Recording cash payments and refunds in Torgsoft

In Torgsoft, the “Фінансовий документ” (“Financial document”) mode lets you view cash transactions and filter them by period, counterparty, cash register, point of sale, business, and document type. For daily monitoring, select the relevant date and counterparty, check receipts and payouts across all relevant tills, and total the transactions subject to the limit. This check depends on complete payment entries and correctly identified parties; a management record by itself does not certify compliance with the law.

If a fiscal registrar is used and configured at the workstation, the “Провести операцію через фіскальний реєстратор” (“Process the transaction through the fiscal registrar”) toggle in the financial document processes a cash deposit or withdrawal and prints the corresponding receipt. This service operation has a different purpose from a fiscal receipt for a sale or refund. Before documenting it, determine what actually happened: a customer payment, a refund, adding change cash, or withdrawing cash.

To use a ПРРО in Torgsoft, you need to activate the additional “Програмний РРО” (“Software settlement transaction registrar”) feature for the required number of workstations, configure the cashier’s key, and select the business unit. The official guide to adding a ПРРО also covers configuring payment methods for sales and refunds. Before use, check that they match the actual payment method and that test mode is off: test receipts are not fiscal receipts, even if they have a number.

What fines apply and what to do after a mistake

Under Article 163-15 of the Code of Ukraine on Administrative Offences, a breach of the cash payment procedure for goods or services, including exceeding the limits, results in a fine for an individual entrepreneur or an officer of a legal entity:

• from UAH 1,700 to UAH 3,400—under part one of the article;
• from UAH 8,500 to UAH 17,000—if the same person committed the same act after already being subject to an administrative penalty for the same violation within the previous year.

The higher fine requires the specified condition of repetition. The article names individual entrepreneurs and officers of legal entities, so it is incorrect to say that every ordinary buyer is automatically fined under this article. If two business entities are involved in the violation, the actions of the responsible persons of each are assessed separately.

For failure to process a required settlement transaction through an РРО or ПРРО, processing it for less than the full amount, or failing to issue the required settlement document, paragraph 1 of Article 17 of Law No. 265/95-ВР provides for a different penalty: 100% of the sale amount involved for the first violation and 150% for each subsequent violation.

Paragraph 14 of Section II, “Final Provisions,” of that Law provides a special exemption from liability for violations in the sale of goods and provision of services committed from 1 October 2023 in temporarily occupied territories or territories of active or possible hostilities. It applies up to and including the relevant end date of occupation, hostilities, or the possibility of hostilities under the official list, and does not cover breaches of settlement procedures in the sale of excisable goods. Before applying the exemption, check the territory, transaction date, and type of goods. This provision does not cancel the cash limits under Regulation No. 148.

If an excess has already occurred, record the actual amounts, dates, parties, and documents, and pass them to an accountant to assess the consequences. Refunding the cash received does not automatically cancel the earlier violation, and the payout itself must also be checked against the limit and properly documented. Depositing the proceeds into an account later does not change the method used for the transaction that already took place.

Official provisions to check for a specific transaction

• NBU Resolution No. 148 dated 29 December 2017 and the Regulation it approved: paragraph 3—definitions; paragraphs 6–7—limits and methods for payments above them; paragraph 8—exceptions; paragraph 10—classification of cash deposited for transfer; paragraph 11—accounting for receipts; paragraph 14—no cash balance limit for individual entrepreneurs; paragraphs 23–29—documents; paragraph 39—no cash book requirement for individual entrepreneurs.
• Law of Ukraine No. 265/95-ВР dated 6 July 1995: Articles 2–3—settlement transactions and seller obligations; Articles 9–10—cases in which registrars are not required; paragraph 1 of Article 17—penalties; paragraphs 13–14 of Section II, “Final Provisions”—offline operating rules and territorial exemption from liability.
• Tax Code of Ukraine No. 2755-VI dated 2 December 2010: paragraph 177.10—income and expense records for entrepreneurs on the general taxation system and documents confirming the origin of goods; paragraph 296.1—income records for entrepreneurs on the single tax; paragraph 296.10—exemption from using an РРО or ПРРО for Group 1; paragraph 5 of Subsection 1 of Section XX—tax-free minimum personal income of UAH 17 for calculating fines. Under Article 163-15, the fine is 100–200 such minimums, or UAH 1,700–3,400, and, in the specified case of a repeat violation, 500–1,000 minimums, or UAH 8,500–17,000.
• Order No. 261 of the Ministry of Finance of Ukraine dated 13 May 2021: standard form for recording income and expenses; paragraph 1 of Section I of the approved Procedure—entries based on primary documents at the end of each working day on which income was received or expenses were incurred.
• Code of Ukraine on Administrative Offences No. 8073-X dated 7 December 1984, Article 163-15: elements of the violation, persons liable, and the condition for the higher fine.