Cash on Delivery via Nova Poshta and NovaPay: Sole Proprietor Account, Receipts, and Accounting

A sole proprietor (ФОП) selling goods with cash on delivery through Nova Poshta must arrange for transfers to be credited to an account used for business activities. The rules of the National Bank of Ukraine (НБУ) require these funds to be credited to the recipient entrepreneur’s account. After the funds are credited, the entrepreneur may withdraw cash separately under the account’s service terms. A personal account must not be used to receive business sales proceeds.

Before your first shipment, check the payment service agreement, account details, and the procedure for providing documents to the buyer. Determine whether you must use a cash register (РРО) or a software cash register (ПРРО) based on the actual payment method, the parties’ roles, and any statutory exceptions. For accounting, link each order to its shipment, payment, fee, account credit, and any possible refund.

How a Sole Proprietor Can Receive Cash on Delivery to an Account

The main rules are set out in the Instruction approved by National Bank of Ukraine Resolution No. 103 of 25.09.2018. Clause 128 governs the acceptance of cash by a payment service provider or its commercial agent to execute a payment transaction. A transfer without opening an account, with cash payout, is provided for individuals, with an express exclusion of sole proprietors and persons carrying out independent professional activities.

Therefore, when a buyer pays cash to a financial service provider for a transfer to an entrepreneur, the funds must be directed to the sole proprietor’s account. This requirement applies to that payment transaction. It does not establish a general ban on entrepreneurs accepting cash from buyers or using cash.

Clause 140 of the same Instruction provides for cash to be issued to an entrepreneur from the entrepreneur’s account. Accordingly, when setting up cash on delivery, distinguish between two events: first, the provider credits the payment to the business account; then, if needed, the account holder arranges a withdrawal. The possibility of receiving cash at a branch does not by itself mean that a transfer is paid out to an entrepreneur without an account being opened.

National Bank of Ukraine Resolution No. 101 of 23.08.2024 amended Instruction No. 103. To determine the applicable rules, use the full text of the Instruction, including all applicable amendments.

Which Account Is Suitable for Cash on Delivery

National Bank of Ukraine Instruction No. 162 of 29.07.2022 distinguishes between a current account opened by a bank and a payment account opened by an authorized non-bank payment service provider. An entrepreneur may choose an eligible provider authorized to open such accounts. The phrase “bank account in a payment system” does not explain what type of account was opened or who services it.

Before activating cash on delivery, we recommend checking the following:

• The account is opened specifically for business activity, and the recipient is identified as you, the sole proprietor.
• The business account number in the agreement matches the details provided by your bank or non-bank provider, and the recipient’s tax information matches your sole proprietor details.
• The selected service allows cash-on-delivery payments to be credited to this account.
• You can obtain statements and fee details to explain the difference between the amount paid by the buyer and the amount credited.

Clauses 10 and 24 of Instruction No. 162 require separate accounts for business activity and personal needs, and prohibit business transactions through personal accounts. The account holder’s sole proprietor status does not change the purpose of a personal card.

When choosing between a bank and a non-bank provider, also consider Clause 7 of Instruction No. 162: funds in a payment account held with a non-bank provider are not covered by the guarantees established by the Law of Ukraine “On the Deposit Guarantee System for Individuals.”

What to Check When Connecting NovaPay

According to the official NovaPay sole proprietor account page, you first need to register in the app and open a personal account. You can then open a separate business account, activate a business card, and enter into a cash-on-delivery agreement. Check that the agreement specifies the business account for receiving sales proceeds.

NovaPay publishes a fee of 0.5% for cash on delivery to a NovaPay sole proprietor account and 1.3% to another account. For a NovaPay sole proprietor account, same-day crediting is provided when the buyer pays for the parcel before 21:00; for later payments, crediting is by 15:00 the following day. A possible delay is stated for drop-off and collection points, usually 2–5 days.

Check the withdrawal method separately. The page lists a fee of 0.25% for withdrawal using a barcode in the app, and 1.5%, with a minimum of 15 hryvnias, for withdrawal through a terminal at a Nova Poshta branch. Before a transaction, verify its terms against your agreement and tariff.

Delivery Agreement and Payment Service Agreement

To organize store operations, we recommend recording separately who transports the goods, who accepts the money, and who issues each document to the buyer. Check the subject matter of the agreements and the parties’ authority. The service name “cash on delivery” or “payment control” does not by itself determine all of the seller’s obligations.

Subclause 8-1 of Clause 4 of Instruction No. 103 permits a written electronic or paper agreement for payment services, including by adhesion. Clauses 8-2 and 8-3 require the provider to disclose the service terms, fees, communication procedures, and dispute resolution process to the user.

Ask the provider to explain in writing the role in which it accepts payment, which documents it generates, how it notifies the seller about payment, and how it refunds the money. Before sales begin, establish under the cash-on-delivery agreement who accepts payment for the goods and who must issue the sales document. If the seller carries out a settlement transaction and is not covered by a statutory exemption, the seller must ensure that the transaction is processed through a cash register or software cash register and that the buyer receives the required document.

Specify in the agreement how payment notifications are sent and how the document is delivered to the buyer. To do this, give your accountant or tax consultant the agreements and samples of the documents issued to buyers.

When a Seller Needs a Cash Register or Software Cash Register

Articles 2 and 3 of the Law of Ukraine No. 265/95-VR of 06.07.1995 link fiscalization to the performance of a settlement transaction. Such transactions include, in particular, accepting cash or payment cards from a buyer for goods. If the seller performs such a transaction and no applicable exception applies, it must be processed for the full purchase amount and the buyer must receive the required settlement document.

To determine the seller’s obligation, distinguish between two situations. If the seller or an authorized representative accepts payment for goods and performs a settlement transaction, it must be processed through a cash register or software cash register unless a statutory exception applies. An electronic settlement document is created at the time of the settlement transaction under Article 2 of Law No. 265/95-VR, and is provided to the buyer when the goods are received under Clause 2 of Article 3. The parties must arrange payment notifications and delivery of the document in compliance with these requirements.

If the financial service provider only transfers funds, and the seller or its authorized representative does not perform a settlement transaction under Article 2 of Law No. 265/95-VR, the seller does not need to use a cash register or software cash register for that incoming payment. To apply this conclusion to cash on delivery through NovaPay, check the specific agreement terms and the documents received by the buyer.

Clause 10 of National Bank of Ukraine Regulation No. 148 treats funds paid by a payer into a provider’s cash desk for transfer to an account as non-cash for the recipient. At the same time, a non-cash payment method does not by itself rule out a settlement transaction. Before the first shipment, obtain the NovaPay cash-on-delivery agreement with all applicable terms, the delivery agreement, and samples of the buyer’s documents.

Together with your accountant, determine whether a participant in the settlement accepts payment for goods on the seller’s behalf, when the seller receives payment notification, and who provides the buyer with the document for the goods.

To determine the procedure for your store, we recommend clarifying the following in order:

1. Whether the seller or an authorized representative receives cash or card payment for the goods.
2. Whether the financial company only transfers funds, or another party to the agreement is authorized to accept payment for the sale and issue the relevant document.
3. Which transaction is confirmed by the document received by the buyer.
4. Whether a specific statutory exception applies to the entrepreneur and the transaction.
5. Which event triggers receipt generation and how the buyer will receive it when collecting the goods.

If the agreements do not provide a clear answer, give them to your accountant or tax consultant together with a description of the flow of funds. When contacting the tax authority, describe the specific situation: payment method, recipient of the funds, role of each participant, documents, and when they are provided. The general question “Is a receipt required for cash on delivery?” leaves these circumstances unclear.

Which Exceptions to Check

The claim that every sole proprietor must use a cash register is too broad. The following rules matter for a retail seller:

• Clause 296.10 of the Tax Code of Ukraine exempts single tax payers in Group 1 from using a cash register or software cash register. This clause alone does not determine whether a specific activity is permitted in Group 1.
• Clause 6 of Article 9 of Law No. 265/95-VR refers to the cases provided by the Tax Code in which entrepreneurs on the single tax system are not required to use a cash register.
• Clause 12 of Article 9 concerns places where goods are received and cash settlements are not made. Its applicability must be assessed together with the actual payment method and the definition of a settlement transaction.
• Clause 14 of Article 9 provides an exception for payments for services made exclusively through remote banking systems and/or money transfer services. There is no basis for extending it to sales of goods.
• Article 10 provides for separate forms and conditions of activity using settlement books and transaction record books instead of a cash register. Before applying this procedure, check whether the government list covers your form of activity, what restrictions it establishes, and whether it sets an annual limit on the total value of settlement transactions.

How to Distinguish an IBAN Payment from a Card Payment

An International Bank Account Number (IBAN) identifies the recipient’s account. To assess a payment, you also need to know how the buyer initiated it and which service was used.

If the buyer independently transfers funds from their account to the seller’s business account using the International Bank Account Number (IBAN) details, without the seller using a card payment acceptance service (acquiring) and without the seller or its representative accepting cash, that payment is not a settlement transaction under Article 2 of Law No. 265/95-VR and does not require a cash register or software cash register.

Assess card payments through a payment service separately: the final credit to an International Bank Account Number (IBAN) does not change how the payment was accepted. For cash on delivery, check the agreements to determine whether the provider only transfers funds or an authorized participant accepts payment for the goods on the seller’s behalf. We recommend keeping the agreement and a sample payment document for each payment method.

Which Documents the Buyer Must Receive

Clause 135 of Instruction No. 103 requires the provider, after accepting cash, to provide a receipt or other document confirming that the funds were deposited. Article 3 of Law No. 265/95-VR separately governs the settlement document for the sale of goods, including goods ordered online.

A transfer document and a sales document confirm different transactions. Check the contents: who is identified as the seller or service provider, what the money was accepted for, and which goods are shown. The presence of a fiscal number on a financial company’s document does not by itself confirm that the seller has met its obligation to provide a document for the goods. Two documents for different transactions do not mean that the store must record sales proceeds from one sale twice.

If the seller is required to issue a fiscal receipt, arrange for it to be provided to the buyer when the goods are received, as required by Clause 2 of Article 3: in paper and/or electronic form, including by sending it to the buyer’s phone number or email address. We recommend collecting the necessary contact details when the order is placed and keeping proof of sending the receipt.

Clause 15 of Article 3 also provides that, at the buyer’s request, the seller must provide a receipt, delivery note, or other settlement document confirming the transfer of ownership. Prepare a document showing the product name, quantity, price, and seller details so the buyer can link the purchase to the order.

How to Reconcile Orders, Cash on Delivery, and Fees

For day-to-day operations, we recommend keeping a register in which one order number links the goods and financial documents. Record the shipment date, buyer’s payment date, and seller’s credit date separately, as they may differ.

We recommend that the employee reconciling payments check daily for delivered shipments without a credit, credits without an identified order, and amount discrepancies. Add a reason and next action to each discrepancy: check the transfer period, obtain a fee breakdown, or contact the provider.

Illustrative example. The buyer paid 2,000 hryvnias for goods. Under the example’s terms, the provider withheld a 10-hryvnia fee from the seller’s funds, so 1,990 hryvnias reached the account: 2,000 − 10 = 1,990. Keep all three amounts in the register. This makes it possible to explain the credit and determine taxable income separately.

How to Determine Income for a Sole Proprietor on the Single Tax System

Under Clauses 292.1 and 292.6 of the Tax Code of Ukraine, the monetary income of an entrepreneur on the single tax system is determined by the funds received, and the date of receipt is the date the funds reach the taxpayer. For cash on delivery, keep the statement for the business account to which the payment was first credited. A later withdrawal of these funds is not a second payment for the same order.

For the sale of the entrepreneur’s own goods, Article 292 does not provide for reducing income by the payment provider’s fee. If the seller’s fee is withheld from the buyer’s payment, determine income based on the full amount paid for the goods, as confirmed by the documents. In the illustrative example above, for a sole proprietor who is not a value added tax payer, this is 2,000 hryvnias. A separate fee paid by the buyer for a transfer service and belonging to the financial provider should not automatically be added to the price of goods sold by the store.

Clause 292.4, which provides for income in the amount of the commission, applies to an attorney-in-fact or agent under the relevant intermediary agreements. Merely engaging a payment company to receive payment does not turn a seller of their own goods into such an intermediary. A value added tax payer must also account for the exclusion of that tax under Subclause 1 of Clause 292.11.

Clause 296.1 allows sole proprietors in Groups 1 and 2 and in Group 3 without value added tax to keep records in any form, recording income monthly. We recommend using a detailed order register to verify the monthly total. For Group 3 payers with value added tax, this clause provides for the standard form for recording income and expenses.

What to Do with Uncollected Parcels and Returns

The Buyer Did Not Collect or Pay for the Goods

We recommend closing the order as undelivered, keeping proof of the return, checking that the goods are complete when received, and making them available for sale again. If no payment was made, the shipment itself does not create monetary income under Clause 292.6. If the buyer made a prepayment, assess it separately.

If a fiscal document has already been created for the order, check which transaction it recorded and whether an adjustment is needed. Determine the adjustment procedure based on the transaction recorded on the receipt, the actual payment, and the return documents. A parcel’s returned status does not by itself confirm an adjustment to fiscal data.

The Buyer Paid for the Goods and Is Returning Them

To substantiate the transaction, we recommend linking the return request or other basis for the return, the goods acceptance document, the original sale, and proof of the refund. Check who actually refunds the buyer so that the seller and payment provider do not both make the payment.

Subclause 5 of Clause 292.11 allows funds to be excluded from income when they are returned on the grounds specified there: return of goods, termination of the agreement, or a written refund request. The documents must confirm the grounds and the actual refund. If you make the refund in a different reporting period, consult your accountant before filing the tax return to agree on how to report the refund and whether previously declared income needs to be amended.

If the return constitutes a settlement transaction under Law No. 265/95-VR, use the appropriate settlement document. A transfer refunded by the financial provider must also be reconciled with the seller’s documents.

What Data the Tax Authority Receives and How to Respond to Requests

Clause 7 of Article 3 of Law No. 265/95-VR provides for the transmission of fiscal data to the controlling authorities. Article 2 allows electronic copies of settlement documents to be used as tax information and during audits. This confirms that the State Tax Service of Ukraine (ДПС) has data on the relevant fiscal transactions.

These rules do not establish unlimited automatic access by the State Tax Service to every person’s bank transactions. Keep documents that explain business receipts and check the legal basis and scope of each request you receive.

Clauses 110–111 of Instruction No. 103 separately require payment providers to monitor transactions and obtain supporting documents based on risk. A provider’s request concerning a transaction does not automatically establish a tax violation. These rules do not specify a universal amount below which business receipts are exempt from documentation or tax.

To respond to a request, we recommend preparing the agreement, order, goods documents, delivery details, payment, fee, and return information. The explanation should make it possible to trace a specific transaction from the order to the credit of funds.

How to Account for Cash on Delivery and Check Receipts in Torgsoft

Torgsoft’s paid “Банківські виписки” (“Bank Statements”) feature supports Privat24, monobank, and UKRSIBBANK. Its license is valid for one year and requires annual payment: in some versions, the option is purchased for each workstation; for a local network or a terminal license server, one corresponding option is required. After activation, configure bank accounts and user permissions in “Налаштування” → “Налаштування виписок по банківських рахунках” (“Settings” → “Bank Account Statement Settings”) using the instructions for your bank.

Check the current price in Torgsoft commercial terms. Incoming payments can be linked to invoices, and previously entered transactions can be marked as transferred. Check the “Враховувати еквайринг під час створення оплати” (“Account for acquiring when creating a payment”) setting, which controls the creation of an acquiring financial document. We recommend reconciling NovaPay statements manually.

If the seller needs fiscal receipts, Torgsoft’s paid “Програмний РРО” (“Software Cash Register”) feature is purchased separately for each device, regardless of the Torgsoft version. The license is valid for one year and requires annual payment; check the current price in Torgsoft commercial terms. After activation, install the cryptographic libraries as instructed, configure the registered cashier’s key, and select the business unit and payment methods. One software cash register cannot be used simultaneously in the Torgsoft desktop program and mobile app. Before sales begin, check the operating mode: test receipts are not fiscal receipts. The documentation also provides for a summary report based on fiscal server data to check sales and returns.

To monitor the movement of funds, use Torgsoft financial documents, linking entries to documents for a specific order. These features help with accounting but do not determine the legal model for cash on delivery. During manual reconciliation, match financial records to the order number, express waybill, and NovaPay statement. Configure receipt generation according to the store’s actual settlement arrangement.

What Liability to Consider When Setting Up Receipts

If using a cash register or software cash register is required, Clause 1 of Article 17 of Law No. 265/95-VR provides, for the violations it defines, including failure to process a transaction or issue the required document, a penalty of 100% of the sale amount for the first violation and 150% for each subsequent violation. The temporary reduced amounts under Clause 15 of the Final Provisions had an end date of 31 July 2025.

Clause 14 of the Final Provisions provides exemption from liability for violations committed from 1 October 2023 during the sale of goods or provision of services in the temporarily occupied territories of Ukraine, territories of active hostilities, and territories of possible hostilities. The exemption applies through the date on which temporary occupation ends, hostilities end, or the possibility of hostilities ceases, as determined under the official list. The exception does not cover settlement violations involving the sale of excisable goods. For a specific place of sale, determine the territory category and applicable dates separately.

Clause 13 of the Final Provisions allows the offline operating time limits for a software cash register established by Article 5 to be exceeded during martial law, a state of emergency, or force majeure circumstances. A range of fiscal numbers must have been obtained for this use. This special condition concerns the duration of offline operation and does not eliminate the requirement to issue settlement documents.

Official Sources for Checking Your Settlement Arrangement

• National Bank of Ukraine Resolution No. 103 of 25.09.2018, “On Approval of the Instruction on the Procedure for Organizing Cash Operations by Banks and Conducting Payment Transactions by Payment Service Providers in Ukraine”: Section I, Clauses 4, 8-2–8-5; Section VI, Clauses 104, 110–111-1, 128, 135, 139–140. The full text reflects amendments made by National Bank of Ukraine Resolution No. 101 of 23.08.2024 and subsequent amendments.
• National Bank of Ukraine Resolution No. 162 of 29.07.2022, “On Approval of the Instruction on the Procedure for Opening and Closing Accounts for Users by Payment Service Providers Servicing Accounts”: Clauses 3, 5, 7–10, 24, 33, 109 — types of accounts, their purposes, and opening accounts for sole proprietors.
• National Bank of Ukraine Resolution No. 148 of 29.12.2017, “On Approval of the Regulation on Cash Transactions in the National Currency in Ukraine”: Clauses 2-1, 4–10 — the scope of transfer regulation, cash settlements, and non-cash receipt of funds deposited by a payer through a provider’s cash desk.
• Law of Ukraine No. 265/95-VR of 06.07.1995, “On the Use of Settlement Transaction Registrars in Trade, Food Service, and Services”: Articles 2, 3, 5, 9, 10, 17; Clauses 13–15 of the Final Provisions — settlement transactions, documents, exceptions, liability, and special conditions.
• Tax Code of Ukraine No. 2755-VI of 02.12.2010: Clauses 292.1, 292.4, 292.6, 292.11, 296.1, 296.10 — income, its receipt date, refunds, and accounting for single tax payers.
• NovaPay: Sole Proprietor Account — connecting cash on delivery, crediting times, statements, and published fees.