Cash Receipt Recording: Rules for Sole Proprietorships, Companies, ECR/PECR, and Cash Revenue Deposits

Cash received by a business from the sale of goods, work, or services must be properly recorded on the day it is received, in the full amount actually received. The method of recording cash receipts depends on how the business operates: for a company that maintains a cash book, this means recording receipts in the cash book based on a cash receipt order; for a separate business unit using an ECR without a cash book — properly generating and retaining fiscal reporting receipts and, if a KORO is used, entering the required information in it; for a PECR — generating fiscal reporting receipts and transmitting fiscal data to the State Tax Service (STS) server. Sole Proprietorships do not maintain a cash book but must keep tax records of income and comply with ECR/PECR requirements where applicable to their activities.

Current legislation does not establish a separate financial penalty specifically for «failure to record cash receipts», incomplete recording, or late recording of cash receipts. However, this does not mean that there is no liability at all: specific violations of cash payment procedures may result in administrative liability, while separate financial penalties apply to sales not processed through an ECR/PECR, transactions recorded for less than their full amount, or failure to issue a proper fiscal receipt. Therefore, business owners must monitor not only the actual amount of cash in the cash register but also whether that amount matches fiscal documents, the cash book, cash orders, and documents confirming the deposit of sales proceeds.

What Is Cash Receipt Recording?

NBU Regulation No. 148 defines cash receipt recording as accounting for the full amount of cash actually received at the cash desk in the accounting document prescribed by law: a cash book, the relevant income and expense record, a fiscal reporting receipt, an electronic fiscal reporting receipt, or a settlement receipt — depending on the payment method used by the business entity.

Recording cash receipts should not be confused with simply placing money in a safe or cash drawer. The law requires actual cash movements to be properly documented using the prescribed procedure.

How Cash Receipts Are Recorded in Different Situations

Recording Cash Receipts by a Company That Maintains a Cash Book

A legal entity that receives and disburses cash through its cash desk using cash orders must maintain a cash book. When cash is received at the company's cash desk, the receipt is documented with a cash receipt order — PKO. Cash disbursements are documented with a cash disbursement order — VKO, or a disbursement statement in cases specified by Regulation No. 148.

Entries must be made in the cash book on the day the money is received or disbursed, based on the relevant cash documents. This means that recording cash actually received cannot be postponed until another business day unless the law provides for a specific exception.

At the end of the working day, the cashier totals the transactions, determines the remaining cash balance, and submits a report together with the cash documents to the accounting department. Through an internal document, the company designates the officials authorized to sign cash documents and establishes procedures for interaction between the cashier, accounting department, and separate business units.

If the company has no cashier on staff or the cashier is temporarily absent, the performance of cashier duties must be formally assigned through an appropriate administrative document issued by the company. This is important not only for accounting purposes but also for clearly identifying the person responsible for the cash actually held.

Cash from an ECR Cash Drawer and Its Transfer to the Company's Cash Desk

Recording a sale through an ECR and transferring money from the ECR cash drawer to the company's main cash desk — are two separate stages.

During a sale, the ECR records the payment transaction and generates a fiscal receipt. If cash is subsequently physically removed from the point of sale for a reason other than refunding a customer, this withdrawal is registered through the ECR/PECR using a «cash withdrawal» operation. When this money reaches the cash desk of a legal entity that maintains a cash book, its receipt is documented using the appropriate cash documents. When cash is deposited directly with a bank, Regulation No. 148 explicitly requires the withdrawal from the point of sale to be recorded using a «cash withdrawal» operation.

A «cash withdrawal» operation is not itself a sale, a product return, or another payment transaction with a customer. It is used to correctly record changes in the actual amount of cash at the point of sale.

Similarly, a «cash deposit» operation is used to register cash added to the point of sale that does not represent revenue from a specific sale.

When a Separate Business Unit Can Operate Without a Cash Book

A separate business unit that processes payments through an ECR and/or settlement receipt books with a KORO but does not document cash receipts and disbursements using cash orders may operate without maintaining a separate cash book. Such a unit must comply with the fiscal accounting and revenue transfer procedures established by the company.

The mere presence of an ECR does not eliminate the requirement for a legal entity to maintain a cash book where the company actually performs cash transactions using PKOs and VKOs. Therefore, the procedure for moving money between the store's cash drawer, the business unit's cash desk, the central cash desk, and the bank should be described in detail in the company's internal regulations.

Z-Reports When Using an ECR or PECR

If payment transactions were carried out during the day, Law No. 265 requires fiscal reporting receipts — Z-reports — to be generated daily in paper and/or electronic form, depending on the type of register. For PECRs, fiscal document data is registered on the fiscal server of the regulatory authority.

A Z-report summarizes the fiscal totals for a shift. It does not replace the cash book of a legal entity if the company is required to maintain one, just as an entry in the cash book does not replace an ECR/PECR fiscal receipt.

In the event of an emergency, an unexpected or prolonged power outage, or other circumstances that objectively make generating a Z-report impossible, the circumstances must be documented, and the business must act in accordance with applicable legislation and current guidance from the STS. This should not become the standard procedure for closing a shift.

What to Do If an ECR Breaks Down or the Power Goes Out

Law No. 265 establishes a special procedure for conventional ECRs. If a register malfunctions, is under repair, or temporarily loses power, payment transactions may be processed within the limits prescribed by law using a properly registered KORO and settlement receipt book or a registered backup ECR.

If a business entity has chosen in advance an operating model under which sales are suspended completely during an ECR breakdown or power outage until a backup ECR is connected or the main register resumes operation, a KORO does not have to be registered for this purpose. However, payments cannot be accepted during that period. The procedure is established by Article 5 of Law No. 265.

Therefore, using an ECR does not automatically make a KORO mandatory for every business owner.

PECR Without Internet Access and Offline Mode

Loss of connection to the fiscal server and a technical malfunction of the PECR itself — are two different situations.

If there is no connection to the STS server, a registered PECR that supports offline operation may continue fiscalizing transactions using a reserved range of fiscal numbers. The general limit for offline operation is no more than 36 consecutive hours and no more than 168 hours during a calendar month. Once the limit is reached, the PECR must stop operating offline until the online connection is restored.

During martial law, a state of emergency, or force majeure circumstances, legislation provides special rules for offline operation. However, fiscal numbers for such receipts must still come from a reserved range. Therefore, businesses cannot assume that they can operate indefinitely «without the server» unless the PECR has been configured accordingly in advance.

If the problem is not a loss of server connectivity but a malfunction of the software register itself, transactions cannot be processed through that PECR until the malfunction is resolved, unless another properly registered payment registration device is available.

How Sole Proprietorships Record Cash Receipts

Sole Proprietorships do not maintain a cash book or prepare PKOs and VKOs in the same way as legal entities. Regulation No. 148 also does not establish a cash balance limit or deadlines for depositing sales proceeds for Sole Proprietorships.

However, this does not mean that cash received can be excluded from tax records.

The following main rules apply to Sole Proprietorships:

• single-tax payers in Groups 1 and 2, as well as Group 3 taxpayers who are not registered for VAT, may keep records in any form by recording income received on a monthly basis;

• Group 3 Sole Proprietorships registered for VAT must keep income and expense records using the standard form approved by Ministry of Finance Order No. 405;

• Sole Proprietorships under the general taxation system must keep income and expense records using the standard form approved by Ministry of Finance Order No. 261, recording transactions based on supporting documents;

• if a Sole Proprietorship is required to use an ECR/PECR, cash sales must be properly fiscalized regardless of how tax records are maintained.

Thus, a legal entity's cash book, a Sole Proprietorship's tax records, and fiscal accounting through an ECR/PECR — are different levels of recordkeeping that should not be confused.

Cash Payment Limits

Regulation No. 148 establishes daily limits for cash payments made under one or more payment documents:

• between two business entities — up to and including UAH 10,000;

• between a business entity and an individual — up to and including UAH 50,000.

These limits apply specifically to cash payments, including those processed through an ECR or documented using a settlement receipt book. Payments exceeding the established limits must be made through payment service providers, either by transferring funds between accounts or by depositing cash with a payment service provider for subsequent crediting to the recipient's account. The daily limit on direct cash payments does not apply to the latter method.

The restrictions do not apply, in particular, to payments to budgets and state special-purpose funds, voluntary donations and charitable assistance, the use of cash for business travel, or payments related to employee remuneration. The complete list of exceptions is provided in paragraph 8 of Section II of Regulation No. 148.

Cash Balance Limits for Companies

Legal entities that conduct cash transactions establish a cash balance limit — the maximum amount of cash that may remain at the company's cash desk outside working hours.

The company must independently develop and approve the procedure for calculating its cash balance limit through an internal document. The limit is determined based on average daily cash receipts or average daily cash disbursements — depending on management's decision — taking into account the company's operating conditions and deadlines for depositing sales proceeds with the bank.

If the volume of cash receipts, operating hours, shift schedules, or other significant conditions change, the company may revise its cash balance limit and deadlines for depositing sales proceeds, documenting the reasons for the decision.

These requirements for establishing a cash balance limit do not apply to Sole Proprietorships.

When a Legal Entity Must Deposit Sales Proceeds with the Bank

The company establishes deadlines for depositing cash proceeds, taking into account its agreement with the bank. Paragraph 48 of Regulation No. 148 provides the following main deadlines:

If a company operates on weekends or public holidays and cannot deposit cash in the usual way under its banking arrangements, Regulation No. 148 allows proceeds to be deposited through an ATM or self-service payment terminal on the day they are received, or directly with the bank during the banking and company's operating hours on the next working day.

Sole Proprietorships are not subject to these statutory deadlines under Regulation No. 148, although they may deposit proceeds with a bank according to their own procedures.

Documents Confirming the Deposit of Sales Proceeds with a Bank

Depending on how the funds are transferred, supporting documents may include:

1. a receipt accompanying a bank cash deposit document, signed by the bank's responsible employees and certified with a seal, if applicable;

2. a receipt or confirmation issued by an ATM or self-service payment terminal;

3. an accompanying cash order for a cash collection bag;

4. a payment terminal receipt — if cash collection is performed in real time using a payment terminal.

When cash is removed from an ECR point of sale for deposit with a bank, a «cash withdrawal» operation must also be performed.

Thus, a bank receipt confirms that the money has been deposited with the bank, but it does not replace the company's cash documents where such documents are required under Regulation No. 148.

How Long to Keep Z-Reports and Other Cash Documents

For electronic Z-reports, Regulation No. 148 refers to the retention periods established by paragraph 44.3 of the Tax Code. Therefore, the rule «keep all Z-reports for exactly 1,095 days» should not automatically be applied to the entire cash and accounting archive.

The Tax Code of Ukraine establishes different minimum retention periods depending on the document category. In particular:

• 1,825 days — for primary documents, accounting registers, financial statements, and other tax-relevant documents of legal entities expressly specified in subparagraph 44.3.2 of the Tax Code of Ukraine;

• 1,095 days — for other documents that do not fall into categories requiring longer retention;

• 1,095 days — for documents related to compliance with other legislation enforced by the tax authorities;

• longer retention periods are established for certain special tax documents.

Where an audit, dispute, or suspension of limitation periods applies, the actual retention period may be extended.

For businesses, the safer approach is to establish a unified internal retention schedule for cash, fiscal, and accounting documents, taking into account the longest applicable retention period for each document category.

Internal Cash Receipt Recording Procedures at a Company

A company must establish its own procedures for recording cash receipts in an internal document. These procedures must comply with Regulation No. 148 and reflect the company's actual operations.

It is advisable to include the following information in this document:

• which cash desks and points of sale the company uses;

• who performs cashier duties and who is authorized to sign PKOs and VKOs;

• how and when money is removed from the ECR cash drawer;

• how the transfer of sales proceeds from a retail outlet to the central cash desk is documented;

• when «cash withdrawal» and «cash deposit» operations are used;

• who generates and checks Z-reports;

• where and in what electronic format fiscal reporting receipts are stored and who is responsible for their safekeeping;

• how employees should act in the event of an ECR malfunction, power outage, or loss of internet access;

• how and within what deadlines cash is deposited with the bank;

• which documents confirm transfers of money between employees, cash desks, and the bank;

• how compliance with the cash balance limit is monitored.

Such a document is particularly important for retail chains where store operating hours do not coincide with the central accounting department's schedule.

Liability for Violations of Cash Handling and ECR Rules

Liability must be distinguished according to the type of violation.

Each individual sale made without an ECR/PECR or without a proper payment document may be treated as a separate violation. Therefore, systematically failing to use an ECR can result in significantly higher penalties than a single incorrectly issued document.

Example from Tax Audit Practice

During an inspection of a filling station in Zaporizhzhia, tax officials identified cash sales of fuel without an ECR/PECR, concealment of part of the cash proceeds, and violations of fuel accounting requirements. According to the STS, the expected penalties for the identified violations amounted to approximately UAH 600,000.

This case demonstrates that an audit examines not just one individual document but also whether actual sales, cash proceeds, ECR/PECR data, and inventory records are consistent.

How to Monitor Revenue, Cash Balances, and Internal Money Transfers in Torgsoft

In Torgsoft, money movements can be recorded separately from inventory movements. Sales proceeds are automatically recorded under the financial analysis category «Sales Revenue», while internal financial transactions — including transfers between cash desks, revenue deposits, cash collection, and transactions between a cash desk and a bank account — are recorded in the software's financial accounting system. This makes it possible to monitor where the money should actually be located after a sale and the subsequent transfer of proceeds.

Torgsoft provides a revenue handover operation for sales staff, and staff access rights can be restricted using roles. Under the software's standard operating logic, the salesperson role may have access to sales, returns, and revenue handover without access to unnecessary financial information. This helps separate the responsibilities of the cashier and business owner and reduces the risk of unauthorized cash transactions.

To monitor actual cash holdings, Torgsoft provides «Cash Register Summary», including cash counting by denomination and indicators showing differences between the actual counted amount and the balance recorded in the system. The «Cash Register Movements» report shows opening and closing cash balances for each day within a selected period. These tools make it possible to regularly reconcile actual cash with accounting records before closing the cash register for the day.

Torgsoft's internal financial documents are used for a company's management accounting. They must not be considered substitutes for PKOs, VKOs, the cash book, an ECR/PECR fiscal receipt, or a bank document where legislation explicitly requires the relevant document to be prepared. Therefore, Torgsoft settings should be aligned with the company's approved cash handling procedures.

Daily Cash Controls: What Business Owners Should Check

Before closing a retail outlet for the day, make sure that:

1. every sale subject to fiscal registration has been processed through an ECR/PECR for the full amount;

2. customers have received paper or electronic payment documents in the prescribed form;

3. the actual cash amount matches ECR/PECR records, taking into account cash deposits, cash withdrawals, and refunds;

4. the required Z-report has been generated;

5. all cash transactions of a legal entity have been properly documented using PKOs, VKOs, and cash book entries, where a cash book is maintained;

6. transfers of sales proceeds between the retail outlet, central cash desk, and bank have been properly documented;

7. the company's established cash balance limit has not been exceeded;

8. the deadline for depositing sales proceeds with the bank has been met;

9. electronic Z-reports, fiscal data, and cash documents are stored in accordance with the prescribed procedures;

10. the actual cash balance matches the internal financial accounting records.

Official Sources

Regulation on Cash Transactions in the National Currency of Ukraine, approved by Resolution of the Board of the National Bank of Ukraine dated December 29, 2017, No. 148. Key provisions: Section I — definitions; paragraphs 6–12 — cash payments and recording cash receipts; paragraph 14 — cash balance limit; paragraphs 26–29 — cash documents and depositing proceeds; paragraphs 39–45¹ — the cash book and cash transactions; paragraphs 48–55 — deadlines for depositing proceeds and cash balance limits.
Official text of Regulation No. 148 on the website of the Verkhovna Rada of Ukraine

Law of Ukraine «On the Use of Registrars of Settlement Transactions in Trade, Catering, and Services» dated July 6, 1995, No. 265/95-VR. Key provisions: Article 3 — obligations when processing payments and generating Z-reports; Article 5 — procedures in the event of ECR malfunctions and power outages; Article 17 — financial penalties.
Official text of Law No. 265/95-VR

Tax Code of Ukraine dated December 2, 2010, No. 2755-VI. Key provisions: Article 44, particularly paragraph 44.3 — document retention periods; Article 177 — accounting for Sole Proprietorships under the general taxation system; Article 296 — accounting for Sole Proprietorships that pay the single tax.
Official text of the Tax Code of Ukraine

Code of Ukraine on Administrative Offenses. Key provisions: Article 163-15 — violations of cash payment procedures; Article 164-4 — late deposit of sales proceeds.
Official text of the Code of Ukraine on Administrative Offenses

Order of the Ministry of Finance of Ukraine dated June 14, 2016, No. 547 — procedures for registering and using ECRs, KOROs, and settlement receipt books.
Official text of Order No. 547

Order of the Ministry of Finance of Ukraine dated June 23, 2020, No. 317 — procedure for registering, maintaining the register of, and using PECRs.
Official text of Order No. 317

Order of the Ministry of Finance of Ukraine dated January 21, 2016, No. 13 — the form and content of payment documents and electronic payment documents, as well as reporting related to KOROs.
Official text of Order No. 13

Public Information and Reference Resource of the STS: official clarification regarding liability for failure to record cash receipts — no separate financial penalty is established specifically for failure to record cash receipts; Articles 163-15 and 164-4 of the Code of Ukraine on Administrative Offenses may apply to specific violations.
STS clarification on liability for failure to record cash receipts