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Store Damaged by Shelling: How to Document Losses, Write Off Property, and Restore Records

12.09.2026 10:00

After shelling, a store owner must protect people, document the damage, and gather records about lost property. Take inventory only when the premises and goods are safely accessible. Based on properly documented results, the business writes off verified losses, assesses usable remnants, and records the changes in its accounts.

If documents have been destroyed, choose the applicable tax procedure. Under the general rule in clause 44.5 of the Tax Code of Ukraine (TCU), a taxpayer notifies the State Tax Service of Ukraine (STS) within five days of the event and restores the documents within the prescribed period. For activities in territories of active hostilities or temporary occupation, subparagraph 69.28 of the TCU applies when its conditions are met. If the consequences of shelling prevent an entrepreneur from filing returns, paying taxes, or meeting other tax obligations on time, the entrepreneur separately substantiates this inability under Procedure No. 225. The tax consequences of a write-off depend on the type of property, tax regime, and supporting documents.

What to do immediately after the event

Do not enter a damaged building to count inventory or retrieve papers while access is unsafe. Before the building is inspected, authorized services check the area for explosive ordnance and neutralize any items found; where necessary, they dismantle dangerous structural parts and search for injured and deceased people. Law enforcement officers carry out the necessary investigative actions. Store employees must not do this work themselves.

The owner or manager may appoint someone to gather available information and keep a list of documents received. In practice, organize records by event, property, missing documents, and tax obligations:

  • Record the store’s address, the date and known time of the event, a description of the damage, and witness contact details. Separate established facts from assumptions.
  • Preserve available photos and videos, camera recordings, correspondence, and notices restricting access. Keep the original files and make copies for working use.
  • Gather documents showing ownership of or the right to use the premises and the purchase of goods and equipment. For leased property or goods belonging to another owner, identify the owner and check the contract’s requirements for notifying them about damage. If the property is insured, promptly check the policy’s method and deadline for notifying the insurer and follow those terms. Taking necessary safety measures into account, find out what evidence the insurer asks you to preserve before cleanup or dismantling.
  • Preserve available accounting data from before the event: goods movements, stock balances, equipment lists, and supplier documents. These will help identify what needs to be checked and restored.
  • Separately list destroyed or inaccessible documents and tax obligations whose deadlines are approaching or have passed.

You can add to the preliminary list of losses. It helps organize the work, but by itself it does not prove that goods were actually on hand, that they were destroyed, or that their cost can be deducted for tax purposes.

How to contact the police and obtain documents

If the circumstances indicate a criminal offense, the property owner, individual entrepreneur (FOP), or business representative files a report with the police or prosecutor. In the report, describe the event, address, damaged or lost property, and known circumstances, and attach available evidence. Also state what harm the event caused you or the business.

An authorized official must accept and register the report. Refusal to accept and register it is not permitted. Obtain a document confirming that the report was submitted and registered, and keep it with a copy of the report.

Under part 1 of Article 214 of the Criminal Procedure Code of Ukraine (CPC), an investigator, inquiry officer, or prosecutor must enter information in the Unified Register of Pretrial Investigations (URPI) without delay, but no later than 24 hours after receiving the report or notification. The applicant is provided with an extract from the URPI 24 hours after the information is entered.

During martial law, the special procedure under Article 615 of the CPC may apply. If technical access to the URPI is unavailable, the investigator, inquiry officer, or prosecutor issues a resolution to begin the investigation and enters the information in the register at the first opportunity. In an urgent case, an inspection of the scene may take place before the resolution, which must then be issued immediately after the inspection.

Victim status and participation in an inspection

A victim may be an individual who suffered property damage, physical harm, or moral harm from an offense, or a legal entity that suffered property damage. A victim’s rights and duties arise when a report is filed about an offense against that person or an application is filed to involve them as a victim. The person who accepts the report or application provides a notice of procedural rights and duties.

If proceedings have already been opened on the basis of someone else’s report, the affected owner or business may apply to be involved as a victim. Under paragraph 5 of part 1 of Article 303 of the CPC, a person denied victim status may appeal the refusal to an investigating judge. Article 304 sets a deadline of 10 days from the day a copy of the resolution is received. Keep the resolution and proof of the date you received it.

If the URPI extract has not arrived, find out whether the information was entered in the register and whether the special procedure under paragraph 1 of part 1 of Article 615 of the CPC was used. Under paragraph 1 of part 1 of Article 303, an applicant, victim, or victim’s representative or legal representative may challenge a failure to enter information before an investigating judge. The general complaint deadline is 10 days from the start of the inaction; under the ordinary procedure, inaction begins after the 24 hours allowed by Article 214 of the CPC have elapsed from submission of the report or notification. Keep proof of when you filed it and any responses received. A lawyer can help determine the deadline in light of the circumstances of the proceedings.

During martial law, paragraph 5 of part 1 of Article 615 of the CPC provides an exception for procedural actions under Articles 220, 221, and 304, including consideration of motions, access to case materials, and filing complaints. If it is objectively impossible to take the relevant action within the prescribed time, it must be taken without delay once possible, but no later than 15 days after martial law ends or is lifted. The circumstances making it impossible must be substantiated.

If you miss the complaint deadline, file a motion to renew it with the complaint and evidence of valid reasons. Under Article 117 of the CPC, renewal is formalized by an order of the investigating judge or court. In proceedings conducted under Article 615, a motion to renew a missed deadline must be filed no later than 60 days after martial law ends or is lifted. Filing the motion does not suspend enforcement of the challenged decision.

An investigator or prosecutor conducts inspections of premises, items, documents, and computer data. An inspection of a store, as a person’s premises other than a dwelling, follows the CPC rules for searching such premises. A victim may be invited to the inspection. If you participate, point out damage, missing equipment, or documents that were overlooked and ask that your statements and comments be included in the inspection record.

Article 615 provides special rules for recording procedural actions. If procedural documents cannot be prepared, law enforcement uses available technical means and prepares the record of the procedural action no later than 72 hours after the action ends. If involving attesting witnesses—people who attest to the course and results of a procedural action—in a search or inspection of premises is objectively impossible or poses a danger to their life or health, the action is conducted without them. In that case, its course and results must be recorded continuously on video using available technical means.

How to obtain inspection materials

A victim may submit evidence and motions for procedural actions. Under Article 220 of the CPC, as a general rule, an investigator, inquiry officer, or prosecutor considers a motion within no more than three days of submission. The person who filed it is notified of the result; a full or partial refusal is formalized in a reasoned resolution. A copy is given to that person or, if delivery is objectively impossible, sent to them.

A victim or their representative or legal representative may challenge failure to consider a motion within the prescribed period before an investigating judge as inaction under paragraph 1 of part 1 of Article 303 of the CPC. Under Article 304, the general complaint deadline is 10 days from the start of inaction, after the consideration period expires. Keep proof that you filed the motion. Under paragraph 7 of part 1 of Article 303, a person whose motion for an investigative (search) or covert investigative (search) action is refused may challenge the refusal, as may their representative, legal representative, or defense counsel. If the refusal is formalized in a resolution, the 10-day period begins on the day a copy is received.

To review investigation materials, submit a relevant motion. Article 221 of the CPC allows you to make extracts and copies, but provides exceptions for materials concerning security measures and materials whose disclosure could harm the investigation. A publicly available document whose original is in the case file cannot be withheld from review on this basis. Article 56 of the CPC also provides a right, after the pretrial investigation is complete, to obtain copies of materials directly concerning the offense against the victim.

What documents to obtain from the State Emergency Service if there was a fire

A fire is documented by a fire report under Procedure No. 2030. An authorized official of the State Emergency Service of Ukraine (SES) prepares it at the site after inspecting it and interviewing the owner, user, balance holder—the person that records the property on its balance sheet—or their representative. The official also interviews witnesses who have information about the fire. Witnesses provide information voluntarily and may refuse. Young children and minors may be interviewed only in compliance with paragraph 7 of Procedure No. 2030 concerning the participation of parents, a legal representative, a teacher or psychologist, and, when necessary, a doctor.

As a general rule, the report is prepared no later than 24 hours after firefighting ends, the fire is reported, or a written application is filed. During martial law or a state of emergency, where sufficient grounds exist, the report may be prepared within one month of the notification or application, with justification for using this extended period. If the owner cannot be identified, the report may omit information about them.

The SES prepares two copies of the report: one is provided to the police, and the other is kept in the fire file. If no investigative task force was at the scene, the report is sent to the relevant police unit no later than three days after it is prepared. An SES official prepares a separate conclusion on the cause of the fire within three days after the report is prepared.

To obtain certified copies of the report and conclusion, the owner, user, balance holder, affected person, or an authorized representative files an application with the SES. Copies are provided within 15 days of receiving the application. A fire report is needed only if there was a fire; for other kinds of destruction, gather documents relevant to the event.

A business entity also keeps records of fires and their consequences, analyzes causes, and takes measures to prevent fires. Paragraphs 4 and 11 of Procedure No. 2030 provide for a fire register under Appendix 4 and monthly submission to the SES of information about fires and their consequences, by the 10th day of the month, in the form prescribed by the Ministry of Internal Affairs.

How to document damage to the store premises

For a damaged building, contact the executive body of the village, settlement, or city council, or, if there is none, the military administration. This authorized body organizes urgent work and inspections under Procedure No. 473. Grounds may include applications from citizens and businesses, information from the SES, police, and other specified sources.

Under the ordinary procedure in Procedure No. 473, buildings and structures in private and municipal ownership are inspected. The ordinary procedure does not apply in territories of active hostilities or temporary occupation if the official List does not specify an end date for the relevant period. For some territories of hostilities, paragraph 6¹ provides for the special inspection described below. The owner should therefore check the territory’s category and dates in the official List.

The authorized body determines whether a commission inspection and/or technical inspection is needed, as well as the sequence and deadlines, in a work plan that takes the damage and available funding into account. After receiving a proper information notice about damaged or destroyed real property under Procedure No. 380, it notifies the applicant by email or at the phone number provided, within 10 calendar days, how and when the inspection will take place. This deadline is for notifying the applicant; when the inspection is completed depends on the applicable procedure.

Commission and technical inspections

Before an inspection, the necessary measures concerning explosive ordnance, initial dismantling of dangerous parts, searches for injured people, and investigative actions must be carried out. The authorized body establishes the commission. It must include at least one specialist with a higher education in the field of “Engineering, Manufacturing and Construction” (G), specializing in “Construction and Civil Engineering” and/or “Architecture and Urban Planning.” If a damaged cultural heritage site must be inspected, representatives of cultural heritage protection authorities are included in the commission. Information about the commission’s membership and work is published on the official websites of the authorized body and regional military administration. A commission member with a conflict of interest must recuse themselves; the commission decides on recusals.

Where possible, a representative of the owner or property manager is involved without voting rights. The commission inspection report identifies the property, its address and characteristics, owner information if available, the extent and probable causes of the damage, restoration work already completed, and conclusions. Photos showing the nature and extent of destruction must be attached to the report. If the report covers several properties, the information for each is provided separately.

The commission enters information from its report in the Register of Damaged and Destroyed Property. If the building is determined to be destroyed, its residential and non-residential premises are considered destroyed. Where possible, the authorized body sends the owner or property manager a copy of the report within three calendar days of its preparation or through the Diia Portal. If the owner’s details or location were unavailable during the inspection, access to the report is provided upon request.

If the commission cannot determine the degree of damage or establish that the building is destroyed, a technical inspection is mandatory, except for the special remote case under subparagraph 2 of paragraph 6¹ of Procedure No. 473. The technical inspection provider prepares a report and an inspection certificate.

An owner or property manager who orders a technical inspection themselves notifies the authorized body in writing of the start of work and, once completed, provides it with one copy of the report and certificate free of charge. If the authorized body orders the inspection, it notifies the owner or property manager in writing of the start of work and provides a copy of the certificate.

When a special inspection is available

Paragraph 6¹ of Procedure No. 473 provides for inspections to document destruction in territories where hostilities are possible with no end date specified and in territories of active hostilities with no end date specified, including where state electronic information resources operate. A commission and/or technical on-site inspection is possible if there is no direct threat to people’s life and health and the safety measures in paragraph 8 can be carried out. In other cases, subparagraph 2 of paragraph 6¹ refers to remote inspection under Resolution No. 815, except for cultural heritage sites. No work plan is prepared for the procedure under paragraph 6¹.

Paragraphs 1–5 of the Special Rules under Resolution No. 815 limit the remote mechanism to residential buildings, detached houses, garden houses, and summer houses, including apartments and other residential premises in such buildings. According to preliminary information from the authorized body, the property must be destroyed, and other types of inspection must be impossible in the relevant territory. These Special Rules do not apply in temporarily occupied territories.

A standalone commercial building or a separate non-residential store unit is not among the property categories defined by Resolution No. 815. If the store is in a residential building, documentary confirmation that the entire building was destroyed matters for its premises: paragraph 8¹ of Procedure No. 473 provides that non-residential premises in a destroyed property are also considered destroyed. Losses of goods and equipment are documented separately.

A building inspection report confirms information about the building. The presence, condition, and losses of store goods and equipment must be documented separately. Filing an information notice about real property does not by itself establish a right to compensation.

How a business documents the loss of accounting records

If primary documents, accounting registers—journals, statements, and other records of business transactions—or reports have gone missing or been destroyed at a business covered by Regulation No. 88, the manager follows paragraph 6.10 of that Regulation. Regulation No. 88 does not apply to banks:

  1. Notify law enforcement in writing.
  2. By order, appoint a commission to identify the missing documents and the reasons for their loss or destruction.
  3. Invite representatives of investigative authorities, security staff, and state fire supervision to participate in the commission’s work.
  4. Approve a report setting out the commission’s findings.
  5. Within 10 days, send a copy of the report to the proper recipients: the authority managing the business, if any, and the relevant territorial tax and customs authorities.

Submit a copy of the report under Regulation No. 88 and the tax notice under clause 44.5 of the TCU separately. The copy of the report is subject to the 10-day period under paragraph 6.10 of Regulation No. 88; the tax notice is due within five days of the event.

Regulation No. 88 governs documentation and accounting for businesses and institutions within its scope. An FOP must meet the tax requirements that apply to them and document the loss; the obligation to create a corporate commission under paragraph 6.10 does not automatically apply to an FOP.

How to take inventory without putting people at risk

Regulation No. 879 applies to legal entities established under Ukrainian law and to the branches and representative offices of foreign legal entities specified in it. For theft, abuse, or damage to property, inventory is conducted as of the day the fact is established, to the extent determined by the manager. In the event of a man-made accident, fire, or natural disaster, inventory is conducted as of the day after the event ends, to the extent determined by the manager. If a court or authorized body requires inventory through a properly issued document, the stated deadline and scope apply, but inventory must not begin before the document is received.

Paragraph 8 of Section I applies to businesses that had or have a registered location in areas of military (combat) operations during martial law, and businesses whose structural units or separate property are located in such areas. It also covers businesses that, since the start of temporary occupation, had their registered location in Crimea, Sevastopol, the occupied territories of Donetsk and Luhansk regions, areas of the Anti-Terrorist Operation, or areas where national security and defense measures were conducted in those regions. Such businesses take inventory when authorized persons can reach the assets, primary documents, and accounting registers recording liabilities and equity safely and without obstruction.

The manager may decide to inventory specifically identified property as of the date its theft, shortage, destruction, or damage is established. This decision must be carried out subject to safe access. Once the obstacles are removed, the business is required to take inventory as of the first day of the month after the month in which access is restored and record the results in the relevant reporting period.

In annual financial statements, information about inaccessible assets, as well as liabilities and equity that cannot be confirmed because the relevant records cannot be accessed, is reported based on accounting records under paragraph 12 of Procedure No. 419. Lack of access alone is not enough to record all property as destroyed.

Who conducts the inventory

The manager establishes an inventory commission by order or another directive. It includes management representatives, accounting staff, and employees familiar with the property, prices, and primary records. Specialists who keep the business’s accounts under contract may also take part in the accounting work.

The commission is headed by the manager, their deputy, or an authorized manager of a structural unit. If the manager keeps the accounting records themselves, they head the commission. All commission members conduct the inventory in the presence of the person with material liability for the property. If a court decision or a requirement from an authorized body applies, that body’s officials may attend with their consent.

If the workload is large, the manager establishes working commissions and approves their membership. A person responsible for property is not included in the working commission checking assets entrusted to them. The same employee may not be appointed chair of a working commission for two consecutive years to check assets held by the same persons responsible for property.

What to check and record

  1. Before counting, check that weighing and measuring equipment works, finish processing available documents on property movements, prepare the latest registers or reports, and determine book balances as of the inventory date.
  2. Group available assets so they can be counted. The commission chair endorses all incoming and outgoing documents attached to registers or reports with their signature, the wording “Before inventory as of,” and the relevant date. Persons responsible for property provide the declarations required by Regulation No. 879 about documents and records of property movements. The declarations must reflect the facts.
  3. Count, weigh, or measure the property physically present. For bulk materials, measurements and technical calculations are permitted; attach the relevant reports and calculations to the inventories.
  4. Record each asset’s name, quantity, unit of measure, condition, and valuation. The quantity of goods in undamaged supplier packaging may be determined from documents, but some of those goods must be physically checked.
  5. Prepare a separate inventory of unfit or spoiled stock. State the reasons, degree and nature of the spoilage, and proposals for a write-down, write-off, or further business use.
  6. For fixed assets that are unfit and cannot be restored, prepare a separate inventory stating when they were put into service and why they are unfit. Account for other owners’ property separately.

Do not copy balances into inventories based on an employee’s statements or accounting software without checking whether the property is physically present. Keep information about assets that remain inaccessible separate from the results of the physical inspection.

Also check whether the event affected cash, monetary documents, and strict-accountability forms. Their presence is recorded in inventory reports. Under paragraph 15 of Section II of Regulation No. 879, such reports are also used to record financial investments and check whether funds in bank accounts, accounts receivable and payable, liabilities, earmarked funding, deferred expenses and income, and provisions are fully recorded. The scope of the check is determined by the grounds for the inventory and the applicable decision of the manager.

All commission members and persons responsible for property sign the inventories and reports. Those responsible also declare that the check took place in their presence, that they have no claims against the commission members, and that they accept the listed assets into their custody. Record any comments before signing. When the responsible person changes, prepare declarations documenting the transfer and receipt of assets.

The accounting department checks the calculations, compares inventories against accounting records, and prepares reconciliation statements. Surpluses and shortages are valued at the amount recorded in the accounting registers. Errors in prices and calculations are corrected and certified by the signatures of all commission members and persons responsible for property; the last page of the inventory must include a signed note that prices and calculations were checked. Prepare separate reconciliation statements for property belonging to others and send copies to the owner.

How to approve the results

In its minutes, the commission explains why inventory results differ from the accounting records and proposes how to record the discrepancies. The minutes explain the reasons for shortages and losses, propose what to write off, and state what measures have already been taken to prevent such losses. If an inventory mix-up resulting in shortages of some goods and surpluses of others is found, the accountant checks all conditions for offsetting them under Regulation No. 879. The commission proposes an offset in its minutes only after this check. The manager approves the minutes within five working days after the inventory is completed.

The accountant records the results in the accounts and financial statements for the period in which the inventory was completed, based on the approved minutes. An inventory after obstacles to access are removed must also follow the special rule in paragraph 8 of Section I of Regulation No. 879.

Natural wastage allowances apply only to shortages actually found and under the conditions in Regulation No. 879, after any permitted offset of shortages and surpluses caused by inventory mix-ups. If there are no applicable allowances, the shortage is above the permitted norm. Destruction by shelling is not documented as natural wastage. A shortage alone also does not establish that a salesperson or other employee is at fault.

How to write off goods and equipment in accounting

A write-off requires documents explaining what happened to the property, how much was lost, and how its value was determined. Add applicable event records to the inventory materials and approved minutes, and document the write-off with a primary document containing the required details.

The rules below apply to legal entities using National Accounting Standards (NAS) 7, “Fixed Assets,” and 9, “Inventories.” They do not apply to budgetary institutions or businesses that are legally required to prepare financial statements under international standards. FOP tax accounting has separate rules.

Completely lost and damaged goods

Under NAS 9, inventory is an asset if the business expects economic benefits from its use and can reliably determine its value. The value of inventory that is completely lost, spoiled, or missing is written off as an expense for the reporting period. Damaged goods that can be used or sold safely and lawfully are valued according to their actual condition. Before returning them to sale, check the safety and quality requirements for that specific category of goods; consult an appropriate specialist if needed.

Inventory is reported at the lower of two amounts: cost or net realizable value. Net realizable value is the expected selling price per unit less expected costs to complete production and sell it. The difference between cost and a lower net realizable value is written off as an expense.

There is a separate rule for materials intended for production. Their cost is not reduced if the finished product is expected to sell for at least its cost. If a fall in the market price of materials means the finished product’s cost will exceed its net realizable value, the materials are valued at net realizable value.

Illustrative example for a business applying NAS 9: a store had 40 units of goods recorded at 600 Ukrainian hryvnias (UAH) per unit, for a total of UAH 24,000. Of these, 10 units were completely destroyed, 10 were damaged, and 20 remained usable with no change in valuation. The expected selling price of a damaged unit is UAH 550, with UAH 50 in selling costs. Its net realizable value is UAH 500.

In this example, the expense from total loss is 10 × 600 = UAH 6,000, and the write-down expense is 10 × (600 − 500) = UAH 1,000. Total expenses are UAH 7,000. The value of the remaining stock is 20 × 600 + 10 × 500 = UAH 17,000. This calculation shows the accounting valuation; whether the expenses are deductible for tax purposes is determined separately.

If, at the balance sheet date, previously written-down inventory remains an asset and its net realizable value has increased, the business increases its value and recognizes other operating income. The increase is limited to the previous write-down.

If the business applies the Chart of Accounts under Instruction No. 291, shortages and losses from spoilage are recorded in subaccount 947. If the persons at fault have not been identified, the written-off carrying amount is also recorded in off-balance-sheet account 07, including subaccount 072. This is a separate record of losses already written off, used to monitor their recovery. Regulation No. 879 requires this record until the persons at fault are identified or the case is closed in accordance with the law.

When the persons required to reimburse the losses are identified, the accountant records the amount due as their debt to the business and as income. For the amount due from those responsible, Instruction No. 291 provides for a debit to subaccount 375, “Settlements for compensation of losses,” and a credit to subaccount 716, “Reimbursement of previously written-off assets,” while simultaneously reducing the amount in subaccount 072. Keep separate records for each loss event and debtor.

Full or partial liquidation of equipment

These rules apply to equipment that the business records as fixed assets. Under NAS 7, an item is written off the balance sheet when it is disposed of or no longer meets the criteria for recognition as an asset. For damaged equipment, assess whether it can be restored and used further.

The financial result from disposal is determined taking into account disposal income, carrying amount, indirect taxes, and related expenses. Add the item’s analytical accounting records to the disposal documents. Under Instruction No. 291, the carrying amount of written-off non-current assets and costs of disassembly or dismantling are recorded in subaccount 976.

If only part of an item is liquidated, reduce its initial or revalued cost and accumulated depreciation by the corresponding amounts for the liquidated part. Assess usable components that remain separately: to recognize them as inventory, the business must expect economic benefits and be able to reliably determine their value.

The carrying amount of written-off property, a loss calculation for a claim or compensation, and a decision to pay compensation serve different purposes. A write-off report does not determine the amount of future reimbursement.

How an FOP records lost goods

An FOP first checks whether they must keep records of goods in stock under clause 12 of Article 3 of the Law on the Use of Registrars of Settlement Transactions in Trade, Catering, and Services No. 265/95-VR. The requirements of this clause do not apply to FOPs who are single-tax payers and are not registered as value added tax (VAT) payers, except those selling:

  • technically complex household goods subject to warranty repair;
  • medicines and medical devices;
  • jewelry and household items made of precious metals, precious stones, precious stones of organogenic origin, and semi-precious stones.

An FOP who has this obligation is subject to Procedure No. 496. They continuously enter information on the receipt and disposal of goods in the Record Form on the basis of primary documents. If there are several sales locations, records are also kept for each location separately, with documents for receipt and internal transfers of goods. Primary documents are mandatory attachments to the Record Form; receipts are recorded before sales begin.

The destruction or loss of goods is documented with a primary document. It states the value at purchase price, as confirmed by the goods records. The supplier and recipient details are not stated in this document. It must include the transaction date, goods description, quantity, and value. For clarity, also state the document’s name and date, units of measure, circumstances of the loss, and the person who prepared it.

The FOP enters the total disposal value shown on the document in column 8 of the Record Form in chronological order. The initial inventory of balances is intended for starting records when the relevant obligation arises. It must not be used to reconstruct missing purchase history at will.

Documenting losses is also necessary for an FOP who is not required to keep goods records under Procedure No. 496: it helps substantiate the event, ownership of the property, and its business use. The specific tax outcome depends on the FOP’s tax regime.

How to restore primary documents

The accountant or FOP prepares a list of missing documents, including periods, counterparties, and known document details. In practice, it is useful to note straight away where each document can be obtained, who is requesting it, and when a response is received.

  • Request counterparts of the documents or properly issued duplicates from suppliers, the landlord, and other counterparties.
  • Obtain available bank statements and payment documents.
  • Check electronic document management systems, saved electronic copies, archives, and backups.
  • Compare restored documents with registers, reports, and goods movements to find gaps and duplicate entries.

Under clause 44.1 of the TCU, tax accounting figures must be based on documents required by law. A bank statement confirms a payment, but documents relevant to the transaction are needed to confirm receipt of specific goods. Goods database data can help restore the records, but it does not replace all primary documentation.

Which details to check

Article 9 of Law No. 996-XIV requires a primary document to state its title, date of preparation, business name, nature and scope of the transaction, unit of measure, positions and surnames of responsible persons, and their signature or other identifying information. Documents subject to requirements established by the National Bank of Ukraine (NBU) are governed by the statutory special rules. An immaterial defect does not by itself mean a transaction will not be recognized if the document identifies a participant and contains the necessary transaction information.

For certain documents on services, work, or rent, the law permits omission of the customer’s or tenant’s job titles, surnames, and signatures. To qualify, the document must state the date or period of the services, work, or rent; a written contract must provide for this documentation method; and the transaction must be recorded in the accounts for the period in which it took place.

This exception does not cover transactions involving public funds, leases of state or municipal property, construction contracts, design and survey work, or contracts for donations, charitable aid, or humanitarian aid. Nor can it be applied to any write-off certificate just because the document was prepared within the business.

How to preserve electronic originals

Under Article 7 of Law No. 851-IV, an electronic original is an electronic copy with mandatory details, including a valid electronic signature. If such a document is stored on several media or sent to several recipients, each relevant electronic copy may be an original. A scan of a paper document does not itself acquire this status.

Restore files together with signatures and the data needed to check integrity and authenticity. Primary documents that software creates automatically in electronic form are used in accounting if they have an electronic signature or seal and comply with legal requirements. Integrity is verified through a signature or seal or other means prescribed by law.

Article 13 of Law No. 851-IV requires electronic documents to be stored in a form that allows their integrity to be checked and the information to be used later. You must be able to restore the original format and retain available data on origin, destination, and the date and time of sending or receipt. The retention period must be at least as long as for the corresponding paper document. Under the conditions specified in this article, documents must be duplicated on several media and periodically copied with integrity checks; if these requirements cannot be met, use the statutory paper-copy storage method.

Which STS notification procedure to use

ProcedureWhat it covers
Clause 44.5 of the TCUGeneral notice of loss, damage, or premature destruction of tax documents and their restoration.
Subparagraph 69.28 of the TCUSpecial substantiation of reported figures when primary documents cannot be produced and the territorial and other conditions of the provision are met.
Subparagraph 69.1 of the TCU and Procedure No. 225Substantiation that specific tax obligations could not be met on time and application of the relevant exemption from liability.

A single event may require several submissions for different purposes. A notice of lost documents does not automatically establish that taxes could not be paid or returns filed. Martial law alone also does not suspend all tax deadlines.

General procedure under clause 44.5 of the TCU

Within five days of the loss, damage, or premature destruction of documents, a taxpayer notifies the controlling authority at the place of registration in writing. Attach properly prepared documents substantiating the event. If the loss concerns relevant customs documents, also notify the authority that completed customs clearance, granted authorization, or issued permission for the relevant simplifications.

Submit the notice under the rules for filing tax returns. Unless the TCU provides otherwise for your case, it may be submitted in person or through an authorized representative, by mail with acknowledgment of receipt and an inventory of the contents, or electronically in compliance with the requirements for electronic documents and signatures. Keep proof of submission and receipt by the authority.

The documents must be restored within 90 calendar days. The period starts on the day after the notice is received by the controlling authority.

If the notice was properly and timely filed and an audit cannot be conducted because documents were lost, the audit period is postponed until the documents are restored and provided, subject to the prescribed rules, but by no more than 120 days. This rule does not cover audits under Article 200 of the TCU.

If the documents are not restored, or are lost, damaged, or prematurely destroyed again after this procedure is used, clause 44.5 treats them as missing when the relevant return is prepared. This rule also applies to compliance with customs, currency, and other legislation monitored by controlling authorities.

Clause 44.6 also treats failure to provide documents before the audit ends or within the period under clause 86.7 as grounds for concluding that those documents were absent when the relevant returns were prepared. This provision has an exception for seizure or other removal by law enforcement. The controlling authority must consider documents submitted in accordance with clause 86.7 after the audit but before it adopts its decision.

Special rules under subparagraph 69.28 of the TCU

Subparagraph 69.28 applies to taxpayers and tax agents that conducted activities in territories of active hostilities or temporarily occupied territories and cannot produce primary documents. The basis may be their loss, destruction, or spoilage, or the inability to remove them from those territories because of risks to life or health or administrative obstacles.

To apply the provision, check the exact settlement or territory, its code, category, dates of the relevant period, and evidence of actual business activity. The List is approved by Ministry for Communities and Territories Development Order No. 376. Resolution No. 1364 distinguishes territories where hostilities are possible, territories of active hostilities, and temporarily occupied territories. The “possible hostilities” category alone does not meet the territorial condition in subparagraph 69.28.

The List states the start and end of the relevant periods. If no end date is given, the territory is considered to remain under the relevant hostilities, risk of hostilities, or occupation. If the end date changes, the new period starts on the day after the previous period ends. Match this information to the store’s activities and the circumstances in which the documents were lost.

A loss unrelated to hostilities in territories specified by the provision does not qualify for subparagraph 69.28. You must also explain why those particular documents cannot be produced.

The taxpayer submits a notice to the controlling authority in free form. It states:

  • the circumstances of the loss and/or inability to remove the documents;
  • the tax or reporting periods to which the documents relate;
  • a general list of primary documents, including their details where possible.

A business’s notice is signed by the manager and chief accountant, as expressly required by subparagraph 69.28. An FOP submits a notice as a taxpayer. Keep a copy of the submission and proof that it was filed. The five-day notification period and 90 calendar days for restoration apply to the general procedure under clause 44.5; subparagraph 69.28 sets no such deadlines of its own.

If you first notified the authority that the documents could not be removed and later learn they were lost, you must submit a subsequent notice of loss describing the circumstances.

What protection a notice under subparagraph 69.28 provides

When the conditions of the provision are met, figures reported for the periods specified in the notice cannot be challenged solely because primary documents are missing. The notice also provides a basis for retaining the expenses, negative corporate income tax base, input VAT credit, and negative VAT balance from prior periods protected by the provision. This protection applies to the relevant figures and does not create a right to add arbitrary expenses.

After a notice stating that documents could not be removed because they were on specified territories, a moratorium applies to documentary audits for the periods identified. Taxpayers who submitted a notice of loss under this provision are not subject to audits for the specified periods, including after martial law ends.

For the periods specified in the notice, subparagraph 69.28 prohibits increases in:

  • declared liabilities for taxes and fees;
  • the declared negative corporate income tax base;
  • the declared VAT refund amount.

The controlling authority bears the burden of proving that there are no grounds to apply subparagraph 69.28. If it refuses to apply the provision, it must issue a reasoned decision stating the grounds and evidence no later than one month after receiving the notice. The decision may be challenged administratively or in court. Until a final decision in the case, the authority may not challenge the reported figures or initiate any audit concerning periods specified in the notice.

Unjustified use of this provision has separate consequences: the taxpayer is treated as evading taxes and is subject to liability under the TCU and other laws. Therefore, describe the territorial condition, circumstances, and connection between the loss and hostilities truthfully and specifically.

How to substantiate inability to meet tax obligations

Procedure No. 225 applies when the consequences of military aggression prevent a specific tax obligation from being met on time. For businesses and FOPs, grounds include, among others, loss of documents or equipment, inability to use or remove them, risks to life and health, lawful prohibitions and restrictions, and other documented force majeure circumstances. This Procedure’s territorial grounds have their own meaning; they are not interchangeable with the conditions in subparagraph 69.28.

Link the event to a specific obligation and its due date. For example, an application should explain which lost documents or equipment prevented a specified return from being filed and why the resources available did not allow it to be filed on time.

Under subparagraph 69.1 of the TCU, substantiated inability exempts the taxpayer from the liability provided there for failing to meet the deadlines for paying taxes, filing returns and documents, registering tax or excise invoices, and fulfilling other covered obligations. The obligations remain in force. If the ability to perform them has not been restored earlier, they must be fulfilled within six months after martial law ends or is lifted.

If the inability concerns only a branch, representative office, excise warehouse, or other structural unit, the protection is limited to activities conducted through that unit. For such a unit, subparagraph 69.1 separately provides exemption from liability for the period until martial law ends or is lifted.

What to include in the application

The application is made in free form but must include the information required by Procedure No. 225:

  • The full business name or the individual’s surname, first name, and patronymic, if any.
  • The code from the Unified State Register of Enterprises and Organizations of Ukraine (EDRPOU) or tax number. For an individual, the registration number of the taxpayer’s registration card (RNOKPP); if the person refused that number due to religious beliefs, notified the tax authority, and has the corresponding passport notation, provide the passport details required by the Procedure.
  • The tax address, name of the controlling authority, and filing date.
  • A concise explanation of the circumstances, with references to supporting evidence.
  • The specific tax obligations that could not be or cannot be fulfilled.
  • Information on the tax periods for which obligations could not be or cannot be fulfilled, or the circumstances specified by the Procedure that caused the inability.
  • A complete list of attachments, including each document’s title, date, number, issuing authority, and page count.
  • The individual’s or business officials’ signatures, and a seal if available.

Attach one or more documents confirming the specific basis for your application. Depending on the event, these may include a fire report and conclusion, an extract from the URPI, property documents, inventory materials, a valuation, insurance policy and claim notice, a notice under clause 44.5 or subparagraph 69.28, or other evidence of loss or inaccessibility.

If an FOP attaches documents listed in paragraph 7 of the list for individuals concerning damage, destruction, or loss of their own property, they must substantiate that the individual owns it and used it in business. For this type of evidence, the property must also be an object of taxation, the sole source for paying taxes, or subject to a tax lien. If the inability is based on other grounds, submit evidence of the circumstances that prevented the specific tax obligation from being met. The Procedure also allows individuals to submit other supporting documents and information together with an identity document.

You do not need every document in the lists under Procedure No. 225 at once. Attach a fire report if there was a fire, and an insurance policy if the property is insured. If a business uses evidence under paragraph 13 of the list for legal entities, the property must be on its balance sheet and be an object of taxation, the sole source for paying taxes, or subject to a tax lien. That paragraph also mentions minutes of the inventory commission signed by a representative of the territorial SES body. Check that the documents substantiate the relevant conditions and are properly prepared. Regulation No. 879 does not set a signature by that representative as a general requirement for an inventory. For an application under Procedure No. 225, you may submit one or more documents sufficient to substantiate your basis.

How to file the application and the deadline for a new case

You may submit the application and documents through the Electronic Cabinet, in paper form to the authority at your tax address or to any service center of a controlling authority, or by mail with acknowledgment of receipt.

For a taxpayer who was fulfilling obligations and then lost that ability because of military aggression, paragraph 6 of Section II sets a deadline for filing the application and evidence: within 60 calendar days from the first day of the month following the month in which the ability to file the application and documents is restored.

The Procedure distinguishes the ability to file an application from the ability to fulfill tax obligations. These abilities may return at different times. Record the actual dates and substantiate what became possible.

Keep original evidence for the limitation period established by the TCU and produce it upon a lawful request from the STS. If the STS issues a reasoned decision that the taxpayer is able to fulfill tax obligations on time, the taxpayer is treated as having that ability under Procedure No. 225.

How the STS reviews the documents

The STS reviews the application and documents within 20 calendar days starting the day after receipt. If the evidence is insufficient, it sends a preliminary decision listing specific additional documents no later than that deadline.

The taxpayer may submit additional documents, explanations, and substantiation within 10 calendar days starting the day after receiving the preliminary decision. The STS reviews them within 20 calendar days starting the day after receipt. If no additional material is filed, the authority decides based on the materials already submitted.

The STS may request additional confirmation from competent authorities. It must establish how the circumstances affected your store and whether you could have met the specific obligation before its due date. The STS must substantiate its conclusion on whether the obligation could be met and explain the grounds for its decision.

The preliminary and final decisions are sent under Article 42 of the TCU. When a document is sent to the Electronic Cabinet, the taxpayer is also notified by email of the document type and the date and time it was sent. A properly generated document may be deemed served under the TCU, so check the cabinet regularly. No response to an initial application under Procedure No. 225 does not by itself mean it was approved.

What to do after the ability to comply is restored

If the ability to fulfill obligations is restored, subparagraph 69.1 of the TCU ties exemption from liability to fulfilling them within 60 calendar days from the first day of the following month. This applies to obligations covered by the provision whose due dates fell between February 24, 2022 and the restoration of the ability to comply. The actual restoration date determines which following month starts the period, regardless of the date of the STS decision.

A taxpayer who received a decision finding inability and then regained the ability to fulfill obligations must also notify the STS no later than 60 calendar days from the first day of the following month. The notice states identifying details, tax address, authority and filing date, date and number of the latest decision finding inability, name and location of the authority that issued it, and the date the ability was restored.

The accountant tracks three separate deadlines: when to file the application and evidence; when to fulfill tax obligations; and when to notify the STS that they can be fulfilled again. The last notice is required for a taxpayer who received an STS decision finding an inability to fulfill those obligations on time.

Tax consequences of a write-off

VAT on destroyed goods

For a VAT payer, clause 32¹ of subsection 2 of Section XX of the TCU provides a special rule. Goods purchased in VAT-taxable transactions and destroyed or lost due to force majeure during martial law or a state of emergency are not considered used in non-taxable transactions or outside business activity. When these conditions are met, clause 198.5 of the TCU does not apply. The conditions concern goods; they should not automatically be extended to services.

Provide documentary evidence of the purchase of the goods in VAT-taxable transactions, their destruction or loss, the causes, and the relevant period. To certify force majeure circumstances, you may apply under Article 14¹ of Law No. 671/97-VR to the Ukrainian Chamber of Commerce and Industry (UCCI) or a regional chamber authorized by it.

Force majeure circumstances are certified by the UCCI and authorized regional chambers. Article 14¹ of Law No. 671/97-VR provides for a certificate to be issued within seven days of the application at cost, and free of charge for small business entities. The application must explain the individual circumstances and how they affected the specific obligation or duty.

Subparagraph 69.29 of subsection 10 of Section XX of the TCU limits VAT refunds: VAT from input tax credit for goods destroyed or lost due to force majeure during martial law is excluded from the calculation of a budget refund. These amounts are carried forward to input tax credit for subsequent periods until fully offset.

VAT on liquidated equipment

Under clause 189.9 of the TCU, liquidation of fixed assets by the taxpayer’s own decision is generally treated as a supply at ordinary prices, no lower than the carrying amount at the time of liquidation. The provision has exceptions:

  • destruction or ruin due to force majeure;
  • liquidation without the taxpayer’s consent, including theft substantiated in accordance with law;
  • submission to the controlling authority of a relevant document showing that the item was destroyed, dismantled, or otherwise transformed so it can no longer be used for its original purpose.

These are alternative grounds. For each item, determine the applicable ground and the required documents.

Under clause 189.10, when components, parts, or waste from the liquidation of non-current assets are recognized for business use, VAT liabilities are not accrued for that transaction. Any subsequent sale of these remnants is assessed as a separate transaction.

Corporate income tax

Under subparagraph 134.1.1 of the TCU, the starting point is the accounting financial result with the tax adjustments provided for by law. Before calculating it, the accountant checks whether the business applies tax differences—adjustments to the accounting financial result provided by the TCU. If the business is entitled not to apply these differences, check whether it has exercised that right.

If the business applies the differences under Article 138, the accountant first determines the item’s tax category. If tax rules classify it as a fixed asset or intangible asset intended for use in business activities, liquidation increases the financial result by its accounting carrying amount and decreases it by its tax carrying amount. These amounts may differ.

For fixed assets and intangible assets not intended for use in business activities, the accounting carrying amount also increases the financial result on liquidation. The decrease under clause 138.2 for original cost and improvements, limited by proceeds, applies to the sale of an item in this category. This sale rule does not apply when the item is destroyed.

FOP on the general tax system

An FOP’s taxable base is net taxable income: revenue less documented expenses related to business activity. Subparagraph 177.4.1 defines expenses directly related to earning income, including the cost of the relevant goods and materials.

A write-off certificate for unsold destroyed goods does not by itself create a universal right to deduct their value from income. Check payment, connection to income, supporting records, and whether the costs were already accounted for. If the FOP meets the conditions in subparagraph 69.28 and filed a notice, the STS cannot challenge reported figures for the specified periods solely because primary documents are missing.

Subparagraph 177.4.5 excludes non-business and undocumented expenses and sets special restrictions for fixed and intangible assets. For purchases of assets subject to depreciation or amortization, apply the relevant depreciation or amortization rules. Their value cannot be deducted arbitrarily in a single amount.

Subparagraph 177.4.6 allows an entrepreneur to elect to deduct depreciation or amortization while keeping separate records and provides for expenses on liquidation of fixed assets to the extent of their carrying amount. Apply this rule subject to the conditions and exclusions in Article 177. In particular, land plots, residential real estate, and passenger cars are not depreciated under this provision; the right to deduct their value upon loss does not automatically follow.

FOP or business on the single tax

Under Article 292 of the TCU, the value of written-off property does not reduce income as an expense. The destruction of goods itself is also not income received. The treatment of any future payment depends on its legal nature and the recipient’s status.

Subparagraph 1 of clause 292.1 excludes insurance payments and insurance indemnities from income for an FOP who is a single-tax payer. For a legal entity, the income definition in subparagraph 2 and the relevant applicable rules govern. The conclusion for an FOP does not automatically extend to a legal entity or every compensation payment.

Writing off warehouse goods in Torgsoft

Once the basis for the loss has been documented and the list of goods agreed, the responsible employee records the write-off in the “Списання товару зі складу” (“Write off goods from warehouse”) mode. Before adding goods, check the document’s purpose, warehouse, date, and number. The software inserts the current accounting center, so check the warehouse separately. Add goods with a scanner or by selecting them from the warehouse.

As soon as goods are added to the write-off document, their warehouse quantity is reduced. Prepare the list and quantities in advance and check them as you enter them. The “Розрахунок собівартості” (“Cost calculation”) button recalculates cost; write-offs are accounted for at cost.

Use “Друк” (“Print”) to produce a certificate at cost or retail prices. For documenting a loss, check the amount, details, and required signatures. If an FOP keeps goods records under Procedure No. 496, the loss document must state the value at purchase price confirmed by those records. Check whether the cost in Torgsoft matches it; printing a certificate at retail prices does not by itself meet this requirement. Include the printed document in the complete set of evidence and accounting records. It does not by itself establish the cause of the loss, restore primary documents, or notify the STS. The sequence of steps is provided in the official instructions for writing off goods.

When liability may apply

Under clause 121.1 of the TCU, a taxpayer may be fined for failing to keep documents for the periods established by Article 44 or failing to provide originals or copies during tax control when the Code requires them. The rule on failure to provide originals has an exception for documents obtained from the Unified Register of Tax Invoices. The fine is UAH 1,020. If the taxpayer has already been fined for the same violation within the preceding year, the fine for a repeat violation is UAH 2,040.

This is not an automatic fine merely for shelling or for missing the five-day notification deadline. A violation must be established, and the applicability of subparagraph 69.28, subparagraph 69.1, and Procedure No. 225 must be considered. Subparagraph 112.8.9 of the TCU also provides exemption from financial liability if the act or omission was caused by force majeure. A connection between the circumstances and the violation must be shown; this provision does not by itself extend filing or payment deadlines.

Administrative liability requires an unlawful culpable act or omission. The Code of Ukraine on Administrative Offenses (CUAO) sets out different violations and the persons who may be held liable:

ProvisionConduct and persons coveredPenalty
Article 163¹ of the CUAOAbsence of tax accounting or violation of tax accounting rules by managers and other officials of businesses, institutions, and organizations.UAH 85–170; for a repeat violation within a year of a penalty for the same offense, UAH 170–255. The article provides an exception where a tax compromise is reached under the relevant provisions of the TCU.
Article 164¹ of the CUAOA citizen fails to file or files late an income declaration, states distorted information in it, or fails to keep or improperly keeps income and expense records for which the law requires a mandatory form.Warning or UAH 51–136; for a repeat violation within a year of a penalty for the same offense, UAH 85–136.
Article 164² of the CUAOFinancial violations specified by the article, including breaches of accounting rules, false reporting data, or a late or improper inventory. The elements of the violation and the authority’s powers must be checked.UAH 136–255. If the person has already been subject to an administrative penalty for one of the violations in part 1 of Article 164² within the preceding year, the fine for a new such violation is UAH 170–340. The state financial control authorities hear these cases under Article 234¹.

For calculating these fines, one non-taxable minimum is UAH 17. This figure is used for the fine amount; the TCU has a different rule for classifying offenses. These penalties do not apply to every affected store merely because property or documents were lost.

How to submit objections or challenge an STS decision

If you receive an audit report

If you disagree with the findings, clause 86.7 of the TCU allows you to submit objections, additional documents, and explanations within 10 working days starting the day after receiving the report or certificate. Submit them to the authority that conducted the audit. You may add evidence that there was no fault, that mitigating circumstances apply, or that grounds for exemption from financial liability exist.

These materials become part of the audit file. The procedure described here has an exception for a documentary unscheduled audit under subparagraph 78.1.5 of the TCU.

If you receive a refusal or another decision

File an administrative complaint with the higher-level controlling authority within 10 working days after the day you receive the decision. Complaints against decisions of territorial STS authorities are filed with the STS of Ukraine. At the same time, notify in writing or by an authorized electronic method the authority whose decision you are challenging.

You may file a complaint in writing or electronically. For electronic filing, comply with the conditions in clause 56.3 of the TCU concerning electronic filing and/or identification in the Electronic Cabinet, as well as the requirements for electronic documents. Attach any required certified copies, calculations, and evidence.

If you miss the deadline, you may file a complaint within six months after it expires, together with a motion to renew the deadline and evidence of valid reasons, if any. The authority renews the deadline if it considers the reasons valid.

In the complaint, you may state that you wish to participate in person, through a representative, or by video conference. The authority must notify you of the date, time, and method of consideration no later than five calendar days beforehand. The absence of a taxpayer who was properly notified does not prevent consideration.

Under clauses 56.8–56.9 of the TCU, the authority must adopt and send a reasoned decision on the complaint within 20 calendar days after receipt. This period may be extended to a total of up to 60 calendar days if the taxpayer is notified before the initial 20-day period ends.

If the decision on the complaint is not sent within the required period, the complaint is deemed fully granted starting the next day after the deadline expires. The same consequence applies if the decision extending the deadline is not sent before the initial period ends. These rules apply to an administrative complaint under the TCU, not to an initial application under Procedure No. 225.

When to go to court

If you challenge in court a decision that does not determine a monetary obligation, including refusal to apply the relevant procedure, check the deadline under Article 122 of the Code of Administrative Procedure of Ukraine (CAP) and any special deadline. The general deadline is six months from the day the person learned or should have learned of the violation of their rights, unless the law provides otherwise.

If a person uses the administrative appeal process provided by law, the general deadline is three months from service of the decision on the complaint. If no decision is made and/or served within the prescribed period, Article 122 provides for six months from filing the complaint. For decisions on monetary tax liabilities, determine the applicable special deadlines separately.

Which documents to keep together

For follow-up with the accountant, STS, insurer, or a representative in the case, gather the materials in one organized file. Depending on the circumstances, it will include:

  • Evidence of the event: the report to law enforcement and proof of acceptance, an extract from the URPI or available documents showing the start of the investigation, inspection materials, the SES report and conclusion if there was a fire, and photos and videos.
  • Property records: proof of ownership or the right to use the property, purchase documents for goods and equipment, accounting registers, inspection reports for the premises, inventory lists, reconciliation statements, minutes, and write-off documents.
  • Records of lost primary documents: the order and commission report for a business, a list of missing documents, requests to counterparties, copies received, and electronic originals.
  • Tax submissions: a notice under the applicable TCU provision, an application under Procedure No. 225 with attachments, proof of filing, preliminary and final decisions, notice that the ability to comply was restored, and appeal materials.

Check the address, date, owner name, property list, quantities, units of measure, and valuation in each document. If details differ, explain why and correct errors properly. This helps distinguish facts already substantiated from documents you still need to obtain. If the store stopped operating, moved, or lost its cash register equipment, separately check with the accountant whether information about the taxable object should be updated using Form No. 20-OPP and whether the applicable procedures for a registrar of settlement transactions (RRO) or software registrar of settlement transactions (PRRO) need to be completed.

Official sources

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