Change to Card 2026: Law, VAT, Accounting & Torgsoft

16.01.2026 14:20

Change to Card in 2026: Proper Implementation (Law, RRO/PRRO, VAT, Accounting, Torgsoft)

When paying for a purchase in a store, the phrase "Can I put the small change on my card?" no longer surprises anyone. More and more retail outlets are expanding their loyalty programs by offering customers the option to credit small change to a "piggy bank"/bonus account to use those funds for future purchases.

In this article, we will break down:

What this operation is from a legal standpoint (and why it is usually not a financial/payment service);

How to correctly process it through RRO/PRRO (Registrar of Settlement Operations);

How it works for VAT purposes;

How to record it in accounting;

And how to configure the feature in Torgsoft.

1. "Change to Card": The Legal Perspective

1.1. Is it a financial service?

As a rule, crediting small change to an internal loyalty balance (which can only be spent with that specific seller) is not a financial service, provided the model does not involve "financial circulation" of funds, does not pay interest, and does not turn into a transfer/storage service for third-party purposes.

The benchmark for evaluation is current financial market regulation. In 2026, the basic law in this regard is the Law of Ukraine "On Financial Services and Financial Companies" No. 1953-IX. (Zakon)

Practical conclusion: If the "piggy bank" is an element of a loyalty program that acts as a prepayment/customer credit with a specific seller, without the ability to "withdraw" these funds as cash, the risk of it being classified as a financial service is typically low.

1.2. Could it become a payment service?

In 2026, it is crucial to consider the Law of Ukraine "On Payment Services" No. 1591-IX. If your "piggy bank" begins to resemble a universal payment instrument (transferable to others, usable outside your network, allowing top-ups/withdrawals), risks arise regarding entering the regulated sphere of payment services. (Zakon)

To stay in the safe zone, the loyalty program rules should state:

The "piggy bank" balance is not electronic money and is not a payment instrument outside the store;

Funds are not subject to cash withdrawal, and no interest is accrued;

Usage is strictly for (partial) payment for the seller's goods/services;

Set expiration dates/cancellation terms with caution to avoid looking like "attracting funds with a repayment obligation."

2. Economic Essence: Prepayment (Gift Certificate Analog)

From a tax logic perspective, the most robust model is to treat "change to card" as a prepayment (advance) for future purchases. This is similar to the approach tax authorities apply to gift certificates: funds are received now, and goods will be shipped later. (zp.tax.gov.ua)

3. RRO/PRRO: Displaying "Change to Card" in a Fiscal Receipt

3.1. Crediting change (topping up the "piggy bank")

The simplest practical model for RRO/PRRO is an individual line item such as:

"Piggy bank top-up (prepayment)"

A common technical workaround is a goods/service entry with a price of 1 UAH and a quantity of 0.37 (for 37 cents). However, in terms of content, it is more correct to call it prepayment so the description does not contradict the accounting and tax essence.

3.2. Paying with "piggy bank" funds

When a customer uses their savings, the receipt must reflect:

The actual goods/services purchased,

And the form/amount of payment, specifically the portion paid via "piggy bank" and the remainder via cash/card (if applicable).

Important: Do not substitute "piggy bank" debits with a "discount" if your program rules define it as a payment (usage of advance). A "discount" has a different legal nature (marketing price correction) and may cause confusion during audits.

4. VAT for VAT Payers: What and When is Taxed

4.1. The "First Event" — At the Moment Change is Credited

If the "piggy bank" is a prepayment, the "first event" rule applies for VAT: VAT liabilities arise on the date of receiving the funds/prepayment (when you credit the change to the customer's balance). Tax authorities explicitly describe this approach using gift certificates as an example.

4.2. The "Second Event" — When the Customer "Redeems" the Piggy Bank

When a customer pays for a purchase using "piggy bank" funds, it is essentially the utilization of a previously received prepayment. For VAT, this is the "second event," which does not create new VAT liabilities for the same amount if they were already accrued at the prepayment stage.

5. Accounting: How to Record the "Piggy Bank"

5.1. Why it isn't revenue at the moment of crediting

According to national accounting standards, prepayment (advance) is not recognized as revenue — revenue arises upon the delivery of goods/services. This is the fundamental logic of NP(S)BO 15 "Revenue."

5.2. Which accounts to use

To reflect advances received, the Chart of Accounts provides sub-account 681 "Settlements on advances received".

Typical scheme (generalized):

Crediting change to "piggy bank" (advance received):
Dr 301/311 (Cash/Bank) → Cr 681 (Advances received).

Goods shipment and advance offset:
Closing the advance obligation (Cr/Dr depending on your workflow), recognizing revenue — at the moment of sale, not at the moment of topping up the "piggy bank."

6. Recommended "Rules" Block for Loyalty Programs

The "Piggy Bank" is an internal accounting balance of the seller's loyalty program.

Funds can only be used to pay for the seller's goods/services at their retail points or online channels.

The balance is not electronic money, not a bank account, and not a payment instrument outside the seller's ecosystem.

7. How to Set Up "Change to Card" in Torgsoft

Go to: Settings → Parameters → Receipt.

Enable checkboxes:
— Change to card
— Add to receipt as a service (so the operation appears as a separate line).

Select change rounding (if needed) and click Record.

8. Summary: What is "Right" in 2026

The most stable interpretation is prepayment (advance), following the logic of gift certificates.

For VAT: Liabilities generally arise on the date change is credited (first event). Redemption is the second event.

In accounting: use 681 "Advances received"; revenue is recognized upon final sale.

Програма обліку товару для інтернет-магазинів, крамниць, торгових точок, складів та виробництва

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