Cash on Delivery via Nova Poshta and NovaPay: Receipts, Income, and Returns

For a cash-on-delivery sale, the seller’s obligation to use a registrar of settlement transactions (РРО; Ukrainian abbreviation for a cash register) or a software registrar of settlement transactions (ПРРО; Ukrainian abbreviation for a software cash register) depends on the actual payment arrangement, agreements with the parties handling delivery and payment, and any statutory exemptions. If the seller must fiscalize the sale, they must issue their own receipt to the buyer before handing over the goods.

When shipping through an intermediary, this may mean issuing the receipt before dispatch and correctly showing that payment is deferred. Once the transfer from NovaPay is credited to the bank account for a sale that has already been fiscalized, that transfer alone does not require another fiscal receipt for the goods.

Link the sales documents, express waybill, fiscal receipt, payment details, and bank credit for every order. An individual entrepreneur (ФОП; Ukrainian abbreviation for individual entrepreneur) paying the single tax recognizes income from cash-on-delivery payments transferred to a bank account on the date the funds are actually credited. Record refusals without payment, returns of paid goods, and corrections to erroneous receipts according to what actually happened.

Determine who delivers the goods and who accepts payment

Start with the sales agreement, delivery agreement, and terms for accepting and transferring funds. The payment method “cash on delivery” describes the sequence of events, but leaves important questions open: in whose name the money is accepted, which transaction the issued document confirms, and who is responsible for fiscalizing the sale of goods.

Under Nova Poshta’s public agreement, the company is defined as a postal operator. The agreement covers accepting, processing, forwarding, and delivering shipments, including courier services. The accession agreement for business clients also governs postal services and the arrangement of transportation for bulky shipments. The company’s status as a postal operator does not by itself determine the seller’s РРО obligations.

In practice, check and document these four conditions for your arrangement:

• who enters into the sales contract with the buyer and is named as the seller in the documents;
• who accepts the buyer’s payment and whether that party acts in its own name;
• whether the intermediary’s document confirms payment for the goods or acceptance of funds for transfer;
• when the seller receives the funds, who pays the fee, and which documents support each amount.

The State Tax Service of Ukraine (ДПС; Ukrainian abbreviation for the tax authority) guidance on delivery with cash on delivery describes different contractual models. In one, a freight forwarder arranges delivery, a financial intermediary transfers the funds, and the seller, if required to do so, issues the fiscal receipt for the goods. In another, under appropriate contractual terms, the courier accepts cash on delivery in its own name and issues a settlement document when handing over the purchase; under the circumstances described by the ДПС, the seller may not need to use an РРО.

Apply a conclusion only if the actual contractual terms match. The example involving a freight forwarder does not establish a universal classification for Nova Poshta. For a courier model, confirm the courier’s authority to accept payment and the content of the document they issue. If the agreements leave these questions open, give them to your accountant or include them in a request for an individual clarification from the ДПС.

Check whether you must use an РРО or ПРРО

For retail sellers in Ukraine, the main rules are set out in Articles 2, 3, and 9 of Law No. 265/95-ВР. If a seller conducts a settlement transaction and no applicable exemption applies, they must process it through a registered РРО or ПРРО for the full amount and provide the buyer with a settlement document. These rules cover goods ordered online.

• Single tax group 1. Paragraph 296.10 of the Tax Code of Ukraine provides that taxpayers in this group do not use an РРО or ПРРО. Eligibility for a particular business activity must be assessed separately under the conditions for remaining in the group.
• Other sellers. Check whether a settlement transaction takes place and whether a specific statutory exemption applies. Crediting cash-on-delivery funds to an account through an intermediary does not by itself establish an exemption.
• Bank transfer. If the buyer transfers funds from their bank account directly to the seller’s bank account using the account details, without card acquiring, the seller does not use an РРО or ПРРО for that transfer. If an intermediary accepts payment when the parcel is handed over, determine the seller’s obligation from the terms for accepting and transferring funds.
• Remote payment for services. The exemption in paragraph 14 of Article 9 of Law No. 265/95-ВР concerns services under the conditions specified there. Selling goods with delivery requires its own basis for exemption.

Before using a ПРРО, notify the ДПС about the business unit as a taxable object using Form No. 20-ОПП, register the ПРРО using an application on Form No. 1-ПРРО, and submit a Form No. 5-ПРРО notice to enter electronic signature or seal certificate details in the register. A cashier may conduct settlement transactions using their own electronic signature or the electronic seal of the entrepreneur or legal entity that registered the ПРРО.

The relevant certificate details must be entered in the register, and the certificate must be valid. Access to the private key for a seal is allowed only to its creator or an authorized representative; protect the key from access by others. These requirements are set out in the Procedure for Using a ПРРО, approved by Order No. 317 of the Ministry of Finance of Ukraine.

Keep documents for the goods, delivery, and transfer of funds separate

The Regulation approved by Order No. 13 of the Ministry of Finance of Ukraine distinguishes a fiscal cash receipt for goods from a receipt for accepting funds for transfer. Each document serves a different purpose. Therefore, the existence of a transfer receipt does not remove the seller’s obligation to issue a fiscal receipt for the goods if that obligation applies under the seller’s sales arrangement.

How to process a cash-on-delivery order before dispatch

For an arrangement in which the seller fiscalizes the goods, set a consistent workflow for the manager, warehouse, and cashier.

1. Confirm the order. Record the goods, quantity, price, any prepayment, the remaining cash-on-delivery amount, delivery method, and who pays for each service. Send the buyer confirmation of the agreed terms.
2. Check the amount to collect. Deduct any prepayment already received from the cost of the goods. Separately account for delivery and transfer services paid by the buyer to their providers. This helps align the order total with the cash-on-delivery amount.
3. Document dispatch and issue the receipt. In the intermediary delivery model described by the ДПС, the seller issues the appropriate receipt before dispatch. For deferred payment, state the payment form and method that match the actual stage of settlement, and record the debt according to the configured workflow. State cash payment only when cash has actually been received.
4. Ensure the buyer receives the receipt. Put a paper receipt in the parcel or send an electronic document to the phone number or email address provided by the buyer so it is available before the goods are handed over.
5. Include supporting documents. Prepare the sales document and information about the seller, returns, and warranty obligations. For goods with a warranty period, provide the required warranty document marked with the sale date.
6. Link the shipment to the order. Record the express waybill and fiscal receipt numbers, the expected transfer amount, and who is responsible for checking payment.

The deadline for providing a document to the buyer follows from Article 3 of Law No. 265/95-ВР and Part 11 of Article 8 of the Law of Ukraine “On Consumer Protection” No. 1023-XII: the buyer must receive the document no later than when the goods are handed over. When arranging electronic delivery, check that sending succeeded and provide a paper option in case of a failure.

After the transfer is credited, reconcile it with the sale already documented. If the sale was properly fiscalized under the applicable cash-on-delivery arrangement, the bank credit clears the debt in the seller’s internal records. Issuing another fiscal receipt for the goods solely because the transfer has arrived would duplicate the same transaction. Document partial settlements using the chosen sequence of prepayment, subsequent payment, and final settlement receipts.

When a single-tax ФОП recognizes income

Under paragraph 292.6 of the Tax Code of Ukraine, monetary income is recognized on the date the taxpayer receives the funds. In an arrangement where NovaPay transfers cash-on-delivery funds to the ФОП’s bank account, use the actual credit date shown in the bank statement. The parcel dispatch date and the date of the goods fiscal receipt may fall on a different day or in a different reporting period.

The ДПС expressly considers an example in which goods with cash on delivery are dispatched and fiscalized at the end of one reporting period, while NovaPay funds reach the bank account in the next. In that arrangement, income arises in the period when the funds actually arrive.

Illustrative example. A store dispatches goods worth UAH 1,800 on September 30 and issues the appropriate receipt. The buyer pays upon receipt on October 2, and UAH 1,800 is credited to the entrepreneur’s bank account on October 3. Under the arrangement described, the ФОП records income on October 3. If the buyer separately paid the service providers for delivery and the transfer fee, those amounts did not reach the seller as payment for the goods.

If the seller pays the fee, check the intermediary’s agreement and report: the full payment for the goods, the withheld amount, and the amount credited. If the documents confirm receipt of sales proceeds with the seller’s fee withheld at the same time, account for revenue before the fee deduction: the cost of a service does not reduce income for a single-tax payer. If the ФОП is registered as a value-added tax (VAT) payer, exclude that tax from income under subparagraph 1 of paragraph 292.11 of the Tax Code of Ukraine.

Determine the income amount from the documents for the specific transaction. Paragraph 292.4 on income in the amount of a fee applies to the relevant intermediary under the agreements specified there.

How to reconcile orders that have been handed over, paid for, or left uncollected

A practical recommendation is to keep a register in which each order has separate delivery and payment statuses. The status “dispatched” leaves open whether the goods were received and whether the money arrived. The following fields are sufficient for tracking:

• order number and express waybill number;
• goods value, prepayment, and cash-on-delivery amount;
• goods fiscal receipt number and how it was delivered;
• date of delivery, refusal, or return of the shipment;
• transfer identifier and amount, and any fee payable by the seller;
• date and amount of the bank credit;
• return or correction documents and any outstanding balance.

Each day, compare deliveries with details of accepted payments, and transfers with the bank statement. If one credit covers several orders, keep a breakdown. At month-end, separately check parcels in transit, orders received by buyers with transfers still expected, and returns. This reconciliation helps explain differences between fiscal sales, inventory movements, and income recognized on a cash basis.

What to do about a refusal, return, or erroneous receipt

For a hardware РРО, paragraphs 7–8 of Section III of the Procedure approved by Order No. 547 of the Ministry of Finance of Ukraine require registering a negative amount when a refund is made or an incorrectly processed amount is cancelled. The “сторно” (reversal) operation is prohibited for such negative amounts on an РРО. If more than UAH 100 is refunded to the buyer, prepare a written statement documenting the disbursement with the required details. A written statement must also be prepared when cancelling an erroneous amount or payment form; keep these statements for three years.

Before the first dispatch, agree with your accountant on how you will handle refusal of unpaid goods for which a receipt showing a debt has already been created. You need a confirmed procedure for your specific ПРРО and receipt type. A fiscal disbursement receipt under Order No. 13 confirms a refund transaction. For an unpaid order that was not collected, document the failed sale and correct the records in line with what actually happened. Recording a payment that was never made creates inaccurate data.

If the amount has already been included in the ФОП’s income, keep the buyer’s request or another documented basis, the goods return documents, and proof of payment. Subparagraph 5 of paragraph 292.11 of the Tax Code provides for excluding from income funds returned under the specified grounds: a goods return, contract termination, or a letter-request for a refund. Align the return in the tax reporting with the periods when the money was received and returned.

Which distance sale terms to communicate to the buyer

Sales to Ukrainian consumers are subject to Ukrainian laws on e-commerce and consumer protection. Under Articles 7 and 11 of Law No. 675-VIII, the seller must provide access to their full details, address, contacts, and tax identifier, information about price and delivery, and, where applicable, licensing details. An order received through an information system must be confirmed promptly. Confirmation of the transaction must include return terms, seller details, how to submit claims, and warranty obligations.

Before concluding a distance contract, tell the buyer the main characteristics of the goods, the full price including delivery, payment and delivery terms, warranty, offer validity period, and the procedure for terminating the agreement. If deliveries are periodic, state the minimum contract term. Confirm this information in writing or by electronic message and keep a record of the agreed content.

Under Article 13 of Law No. 1023-XII, as a general rule, a consumer may notify the seller of termination of a distance contract within 14 days from confirmation of the information or receipt of the goods or first delivery. Returning a physical item also indicates termination. If the information was not properly confirmed, the consumer has 90 days to terminate the contract from receipt of that information; for physical goods, the 90 days run from receipt of the goods or first delivery. If the seller corrects the confirmation within those 90 days, the consumer has 14 days from receipt of the corrected confirmation.

When accepting returns, take into account the conditions in Parts 5–9 of Article 12, which apply to distance contracts. The consumer must keep the goods in an unchanged condition. Opening the packaging, inspecting the goods, and checking them do not remove the right to terminate the contract, even if these actions reduce the goods’ value. This right also remains if the goods are destroyed, damaged, or spoiled through no fault of the consumer.

The seller bears the cost of return. The consumer states where the goods can be collected; the agreement may provide for postal returns. The seller must arrange to collect the goods within the applicable period, counted from the day the consumer receives them. Sixty days after receipt, the consumer’s obligation to keep the goods ends. If the seller has not taken steps to retrieve the goods within that period, the goods become the consumer’s property without any obligation to pay for them.

If the seller did not provide the document or information confirmation required by Part 6 of Article 12, as applicable to the distance contract, the transaction does not create obligations for the consumer. After the consumer notifies the seller that the contract is invalid, the seller must refund the money received and reimburse the cost of returning the goods within 30 days of receiving the notice.

If the deadline for refunding the money is breached, the consumer is entitled to a penalty of 1% of the goods’ value for each day of delay.

Before applying an exception to the right to terminate, check Part 5 of Article 13. It covers, among other cases, goods made or altered to order where resale to others is impossible or would cause significant losses; goods priced according to financial markets; unsealed media of the types specified by law; delivery of periodicals; and other expressly listed cases. Early electronic delivery or provision of a service requires the consent and notice specified by law. The contract may give the consumer a broader right to terminate.

Unless a different period has been agreed, the goods must be delivered within a reasonable time, and no later than 30 days after the consumer agrees to conclude the contract. If the contract cannot be performed because the ordered goods are unavailable, notify the buyer immediately and no later than 30 days after receiving their consent to conclude the contract. A substitute may be supplied under a condition disclosed in advance in the contract, if it suits the intended use, is of the same or better quality, and costs no more than the item ordered.

Handle claims about defects under Article 8. During the warranty period, the consumer may demand a proportionate price reduction, free repair, or reimbursement of repair costs. If there is a substantial defect attributable to the manufacturer or seller, or the goods are counterfeit, as confirmed by an expert examination where necessary, the consumer may demand a replacement or contract termination with a refund. The seller may reject claims about defects if they prove the defects resulted from the consumer’s failure to follow instructions for use or storage.

The consumer has the right to take part in the quality check personally or through a representative. If the contract is terminated due to defects, refund the money on the day of termination; if this is impossible, agree on another period of no more than seven days. If the price has increased, calculate the refund using the goods’ price when the claim is made; if it has decreased, use the price at the time of purchase.

Recording cash on delivery and ПРРО receipts in Torgsoft

In Torgsoft, you can use the “Торгівля з випискою рахунка” mode (the Ukrainian interface label meaning “Trading with invoice issuance”) for orders with a prepayment and subsequent settlement: create an invoice, prepare a delivery note, and record payments. If the ПРРО option is connected and configured, the software generates receipts for prepayment, subsequent payments, and final settlement. The official help page on receipts for trading with invoice issuance describes how to generate a receipt for the payment amount or for the payment plus debt.

In the latter case, you must specify the form and method of payment for the debt; this receipt is considered final, and printing another receipt for a later payment on the same delivery note is no longer available.

Before using this feature, agree with your accountant on the fiscalization sequence for your delivery arrangement. In the menu “Налаштування — Параметри — Чек” (the Ukrainian interface labels meaning “Settings — Parameters — Receipt”), for “Умови друку чека в Торгівлі з випискою рахунка” (the Ukrainian label meaning “Receipt printing conditions for Trading with invoice issuance”), select “Пропонувати друк” (“Offer to print”) or “Друк чека завжди” (“Always print receipt”): the official help page specifies these values for working with a ПРРО.

Separately configure printing of prepayment receipts and delivery-note receipts, as well as payment methods. Check the fiscalization settings for the goods: for a mixed invoice, the software allocates the prepayment proportionally between the fiscal and non-fiscal portions according to their value. Payments with receipts already generated must be refunded through the corresponding operations, because deleting a payment record leaves the fiscal receipt valid. Reconcile the cash-on-delivery bank credit against the invoice, delivery note, and receipts already issued.

The “Програмний РРО” option (the Ukrainian interface label meaning “Software cash register”) requires a separate paid annual license for each workstation (cash register) where fiscalization is conducted; it works with Torgsoft Start, Ultra, and Terminal licenses. You need ПРРО registration and a qualified electronic signature supported by Torgsoft. After configuring a template and messaging service and connecting the “Масові розсилки клієнтам” option (the Ukrainian label meaning “Bulk mailings to clients”), you can send electronic receipts. Make refunds through a bank or payment provider as a separate payment action, and reconcile them with the return document in the software.

How to retain documents and monitor cash register operations

A practical recommendation is to keep, by order number, the confirmation of terms, dispatch document, express waybill, fiscal receipt for the goods, transfer details, bank statement, and return documents. Collect and share with delivery participants only the buyer data required to fulfill the order; establish a lawful basis and purpose for processing in accordance with Articles 6, 11, and 14 of Law No. 2297-VI “On Personal Data Protection”.

For days with settlement transactions, create fiscal reporting receipts and check that data has been transmitted. Hardware РРО control tapes must be kept for three years. ПРРО documents created offline must be kept until they are transmitted to the fiscal server and delivery is confirmed. Keep ФОП tax documents for which paragraph 44.3 of the Tax Code sets a minimum period of 1,095 days for at least that long from the date the report for which they were used is filed.

If the report was not filed, count from its statutory filing deadline. For documents relating to compliance with other legislation monitored by tax authorities, count from the date of the relevant business transaction; for permits, count from the end of their validity period. Account for extensions of these periods where provided by law, and keep documents related to an audit or dispute until the relevant proceedings are complete.

If the connection to the fiscal server is lost, offline ПРРО operation requires a reserved range of fiscal numbers. Article 5 of Law No. 265/95-ВР sets general limits of 36 consecutive hours and 168 hours per month; paragraph 13 of the Final Provisions allows these periods to be exceeded when specified special circumstances apply, including the legal regime of martial law. Check your ПРРО’s technical limits before working offline.

The official Torgsoft option page sets limits of 36 consecutive hours and 168 hours in a month: once they are reached, the software requires you to restore the server connection to continue working. The statutory permission to exceed these periods does not itself change the software limits. After the connection is restored, ensure that within an hour you transmit to the fiscal server a package containing Form No.

4-ПРРО notices for starting and ending offline work, along with settlement documents and fiscal reporting receipts created in that mode. On the day a fault is discovered, send a Form No. 2-ПРРО notice to the supervisory authority, the ПРРО manufacturer, and/or the service center, if there is one. Stop settlement transactions until the fault is fixed or a registered backup РРО is connected. After the fault is fixed, submit a Form No.

1-ПРРО application marked “Відновлення роботи” (the Ukrainian label meaning “Restore operation”). If the application is not received within a month, the ПРРО registration will be cancelled.

For failure to process a settlement transaction, processing it for less than the full amount, or failing to issue the required document, paragraph 1 of Article 17 of Law No. 265/95-ВР provides for a penalty of 100% of the value of the non-compliant sale for the first violation and 150% for each subsequent violation. From October 1, 2023, paragraph 14 of Section II of Ukrainian Law No. 265/95-ВР exempts businesses from liability for violations of this Law committed when selling goods or providing services in specified territories of Ukraine.

In temporarily occupied territories, the exemption applies through the date temporary occupation of the relevant territory ends; in territories of active hostilities, through the date hostilities in the relevant territory end; and in territories of possible hostilities, through the date the possibility of hostilities in the relevant territory ceases. The exemption does not cover violations of the procedure for conducting settlement transactions when selling excisable goods.

Before applying it, check the category of the territory where the sale or service took place and the relevant date against the official list of territories established under the procedure set by the Cabinet of Ministers of Ukraine. Martial law alone does not exempt all sellers from liability.

Official sources for processing cash on delivery

• Law of Ukraine No. 265/95-ВР “On the Use of Registrars of Settlement Transactions in Trade, Food Service, and Services”: Articles 2, 3, 5, 9, and 17; paragraphs 13–14 of the Final Provisions.
• Tax Code of Ukraine No. 2755-VI: Article 44; paragraphs 292.1, 292.4, and 292.6; subparagraph 5 of paragraph 292.11; paragraphs 296.1 and 296.10.
• Ministry of Finance of Ukraine Order No. 13, Regulation on the Form and Content of Settlement Documents: Sections I–III and VI.
• Ministry of Finance of Ukraine Order No. 547, Procedure for Registration and Use of an РРО: Section III, including paragraphs 5 and 7–8.
• Ministry of Finance of Ukraine Order No. 317, Procedure for Registration, Maintenance of the Register, and Use of a ПРРО: Sections II, IV, and V.
• Law of Ukraine No. 1023-XII “On Consumer Protection”: Articles 8, 13, and 15; Parts 5–9 of Article 12 as they relate to Article 13.
• Law of Ukraine No. 675-VIII “On Electronic Commerce”: Articles 7, 11, and 13.
• Law of Ukraine No. 2297-VI “On Personal Data Protection”: Articles 6, 11, and 14.
• ДПС guidance on РРО use for delivery of goods with cash on delivery and ДПС guidance on the income date for a ФОП receiving a NovaPay transfer.