Sole Proprietors Abroad, pECR, Ukrposhta, Bank Transfers and VAT: What Has Changed for Entrepreneurs

Being abroad does not in itself prevent a Sole Proprietorship from conducting business in Ukraine, accepting online payments, issuing PECR receipts, or arranging the delivery of goods in Ukraine. At the same time, government authorities, banks, and payment institutions have greater technical capabilities to cross-check different data: the State Tax Service receives border-crossing information more quickly, PECR transmits fiscal data to the tax authority’s server, payment transactions contain identification details, and banks apply ongoing financial monitoring.

For an entrepreneur, the main risk does not arise from the mere fact of being abroad, using Ukrposhta, or using a bank card. What matters is whether the actual operation of the store, employees and contractors, registered business units, PECRs and cashiers, payment methods, product documents, shipments, and bank receipts are consistent with one another. Two important points should also be taken into account: the UAH 1 million rule for mandatory VAT registration does not apply to single tax payers in groups one through three, and the August changes in Ukrposhta’s operations did not create a separate automatic «register of sellers for the State Tax Service».

What changed in August 2026

Three changes are of the greatest practical importance to entrepreneurs.

First, the State Tax Service and the State Border Guard Service automated interagency information exchange. Previously, requests were processed through correspondence and manually; now, a response to an electronic request can be generated by the system within seconds. At the same time, the State Tax Service explicitly emphasizes that the new mechanism does not create new inspections, additional powers, or new restrictions on crossing the border.

Second, payment operators began bringing their procedures into line with the NBU requirements regarding the details of payment instructions for money transfers without opening an account. Against this background, from August 1 Ukrposhta changed the display of personal data on certain paper receipts, including when receiving cash-on-delivery shipments. Following subsequent changes, the company simplified identification for certain small cash payments, but cash on delivery was not included in the list of announced simplifications.

Third, from August 11 the NBU expanded the possibilities for using corporate and business cards abroad. In particular, the limit for payments for goods, works, and services from hryvnia accounts using corporate cards is up to UAH 400,000 equivalent per calendar month, while the limit for withdrawing cash abroad from a hryvnia account using a corporate payment instrument is up to UAH 140,000 equivalent per month.

What exactly can the State Tax Service obtain about border crossings

The automated mechanism between the State Tax Service and the State Border Guard Service does not provide tax officials with open access to the movements of all citizens.

According to official information from the State Tax Service:

• a request is generated for one specific person or one vehicle;

• there must be a legal basis for the request;

• the request is signed with the qualified electronic signature of a specific State Tax Service official;

• an electronic timestamp is applied;

• users’ actions are recorded in electronic audit logs;

• information is transmitted through a secure communication channel.

The State Tax Service lists determining tax residency and detecting potentially fictitious business transactions among the purposes for using this data.

The existence of tax debt in itself does not mean that a person is prohibited from leaving Ukraine. The automation of information exchange has not changed the rules for crossing the border.

Sole Proprietorship abroad: is tax residency lost after 183 days

No. The 183-day rule is not an independent universal test under which a Ukrainian Sole Proprietorship automatically becomes a non-resident.

Subparagraph 14.1.213 of the Tax Code establishes a sequence of criteria. First, the place of residence is taken into account. If a person has a place of residence in two countries — the place of permanent residence is considered. If permanent housing is available in two countries — the center of vital interests is considered, meaning the closer personal and economic ties.

Only if the center of vital interests cannot be determined or there is no permanent place of residence in either country is the criterion of staying in Ukraine for at least 183 days during the tax year applied, including the days of arrival and departure.

The Tax Code separately provides that the permanent residence of family members in Ukraine or the registration of a person as an entrepreneur may be a sufficient, though not exclusive, indication that the center of vital interests is located in Ukraine.

Therefore, staying outside Ukraine for more than 183 days does not automatically mean losing Ukrainian tax resident status. If another country simultaneously recognizes the person as its tax resident, the relevant international double taxation treaty must additionally be applied.

A Sole Proprietorship is abroad while the PECR issues receipts in Ukraine

The mere fact of such a situation is not defined as a violation under Law No. 265.

A Sole Proprietorship may remotely:

• manage an online store;

• accept orders;

• use automated fiscalization;

• operate through duly employed staff;

• outsource the storage, packing, and delivery of goods to a third-party contractor under an agreement;

• monitor sales through an information system.

For a PECR, what matters is not the actual location of the smartphone or laptop owner, but whether the process itself is properly organized and documented.

Before registering a PECR, the business unit must be registered with the State Tax Service, including through notification Form No. 20-OPP. The PECR is registered to the relevant business unit. For online trade, the State Tax Service separately explains the rules for registering stationary and mobile PECRs depending on the actual sales and delivery model.

Therefore, issues primarily arise when the actual organization of the business does not correspond to the registered model. For example:

• a physical store operates every day, but it is unclear who actually serves customers;

• one person conducts the sale, while receipts are signed with another person’s electronic signature;

• goods are packed and handed over to the carrier every day, but there is no employee or agreement with a contractor performing this work;

• one business unit is registered, while actual settlements are systematically carried out at other locations;

• PECR data, inventory records, shipments, and bank receipts differ substantially from one another.

Who can work with a PECR

The State Tax Service receives information on electronic signatures and seals that will be used with a PECR through notification Form No. 5-PECR J/F1391802.

Persons whose certificates are entered into the PECR Register on the basis of such notification may conduct settlement transactions using the business entity’s PECR during the relevant shifts.

If a receipt is issued by an employee, the proper model is for that employee to have their own electronic signature and for information about their certificate to be submitted for use with the PECR.

A Sole Proprietorship’s personal key and password must not be transferred to an employee. The Law on Electronic Identification and Electronic Trust Services requires the user to ensure the confidentiality of the private key and prevent access to it by other persons.

If a Sole Proprietorship has no employees but the store is operating

The absence of hired employees is not in itself a violation: a Sole Proprietorship may work personally or engage independent contractors under civil-law or commercial agreements, provided that the actual nature of the relationship corresponds to such a model.

However, if a person is actually working as an employee, they may not be allowed to work without formalizing the employment relationship. Article 24 of the Labor Code requires an employment agreement to be formalized by an order or directive and the State Tax Service to be notified of the employee’s hiring before the employee starts work. This requirement also applies during martial law.

For a store whose owner remains abroad for a prolonged period, it is advisable to have a clear documented answer to at least the following questions:

• who opens and closes the retail outlet;

• who accepts payments;

• who works with the PECR;

• who hands the goods to the customer;

• who prepares online orders;

• who hands parcels over to the carrier;

• under which employment or other agreement this person performs the relevant functions.

A Sole Proprietorship’s personal qualified electronic signature must not be transferred to an employee or accountant

The private key of a qualified electronic signature must remain under the control of its owner. The obligation to prevent access by other persons is expressly provided for by legislation on electronic trust services.

Therefore, a scheme in which the owner of a Sole Proprietorship goes abroad, leaves their key file and password with a salesperson, and the salesperson uses them every day to sign receipts or documents creates a significant legal and evidentiary risk.

For a PECR, the certificates of authorized cashiers must be registered through Form No. 5-PECR instead of transferring the entrepreneur’s personal key to them.

How cash on delivery through Ukrposhta works and when the seller’s receipt is required

The term «cash on delivery» itself does not determine whether an ECR or PECR must be used. What matters is the contractual model: who participates in the settlement for the goods, who accepts the customer’s money, and how the funds are transferred to the seller.

In its explanation regarding an online store, the State Tax Service describes a situation in which the buyer pays the postal operator when receiving the goods, and the operator transfers the money to the store’s bank account. The State Tax Service considers that in such a case the store receives its revenue in non-cash form through an intermediary and issues its own fiscal receipt. The payment method field may state, in particular, «cash on delivery» or «non-cash payment».

At the same time, a document issued by the postal or payment operator confirming acceptance of the funds and the seller’s fiscal document relate to different transactions. It should not be automatically assumed that a Ukrposhta receipt always replaces the seller’s fiscal receipt.

The State Tax Service also emphasizes that the specific obligation to use an ECR for delivery depends on the terms of the seller’s agreements with the carrier, courier, freight forwarder, or another party involved in the settlement.

Therefore, an online store should check its specific contractual model with Ukrposhta or another operator rather than relying solely on the name of the «cash on delivery» service.

Does Ukrposhta «report» sellers to the tax authorities

The regulatory changes and official August announcements contain no rule establishing a new special automatic register of all Ukrposhta sellers to be transferred to the State Tax Service.

The changes primarily concerned payment information and identification details.

NBU Resolution No. 20 regulated the mandatory details of payment instructions for money transfers without opening an account. Providers of such payment services were given six months to bring their operations into compliance with the new requirements.

Ukrposhta reported that from August 1 additional personal data of the payer began to be displayed on paper receipts for certain transactions, including when receiving cash-on-delivery shipments. Following public discussion, the company changed the procedure for some small transactions.

The simplifications were announced, in particular, for cash payments for mobile communications, utilities, and certain other services up to UAH 5,000, as well as cash top-ups of bank cards up to UAH 5,000. Cash on delivery was not included in the published list of these exceptions.

This means that cash-on-delivery shipments are becoming a more structured payment transaction in terms of identification and payment data. However, it is legally incorrect to describe this as a new automatic channel for transferring a list of sellers to the tax authorities.

What receipt should the buyer receive

If a transaction is subject to fiscalization, the seller must process it through a registered ECR or PECR for the full amount and provide the buyer with a settlement document in paper or electronic form.

For an electronic receipt, the State Tax Service emphasizes that the seller must ensure that it is sent to the buyer, including to the provided mobile phone number or email address. Merely placing the receipt somewhere on a website without properly providing it to the buyer is insufficient.

The form and mandatory details of fiscal cash register receipts are determined by the Regulation approved by Ministry of Finance Order No. 13.

When an IBAN transfer can be received without an ECR/PECR

Not every crediting of funds to an account constitutes a settlement transaction within the meaning of Law No. 265.

If the seller provides the buyer with the full details of their current account in IBAN format and the buyer makes a standard bank transfer to that account, the State Tax Service explains that such a transaction does not require the use of an ECR/PECR.

A different situation arises in the case of:

• cash payment;

• payment by bank card;

• acquiring;

• use of an electronic payment instrument;

• other transactions that meet the definition of a settlement transaction.

The State Tax Service separately emphasizes that a bank’s «key card» is an electronic payment instrument. Therefore, providing a buyer with card details cannot automatically be treated as equivalent to a standard bank transfer to a current account using full IBAN details.

Can a bank refuse to process an automatic payment by a Sole Proprietorship

A scheduled payment or automatic payment order does not eliminate bank control.

Law No. 361-IX requires banks and other primary financial monitoring entities to continuously analyze customer transactions for consistency with information about the customer, the nature of their activity, and their risk level. Where necessary, the bank also takes into account information about the source of funds. The scope of the review is determined by the customer’s risk profile, the purpose of the relationship, transaction amounts, and transaction frequency.

Therefore, a bank may request documents explaining the economic substance of a payment, such as an agreement, invoice, delivery note, acceptance certificate, supply documents, or other evidence of a business transaction.

No single new statutory monthly limit on all transfers by all Sole Proprietorships and legal entities was introduced in August–September 2026.

Business accounts should also not be confused with restrictions on transfers between individuals’ accounts. The NBU’s temporary regulatory limit of UAH 150,000 per month for P2P transfers by individuals ceased to apply on April 1, 2025. Banks nevertheless continue to apply risk-based monitoring and may establish service conditions in accordance with legislation and the customer agreement.

Corporate cards abroad: what limits apply

NBU Resolution No. 18, as amended following the changes of August 10, allows payments abroad for goods, works, and services using corporate or business electronic payment instruments from hryvnia accounts within the equivalent of UAH 400,000 per calendar month across all such hryvnia accounts held by the customer with the bank.

For card payments from foreign currency accounts, no general limit is established under this provision, except for the special cases defined in subparagraphs 9-2 and 9-3 of paragraph 14 of Resolution No. 18.

Separately, the limit for withdrawing cash abroad from a hryvnia account using a corporate or business card is up to the equivalent of UAH 140,000 per calendar month.

The NBU’s authorization to conduct a transaction does not replace documents confirming its business purpose. If a card is used to pay business expenses, documents should be retained that make it possible to identify the purchase, its amount, and its connection with the activities of the enterprise or Sole Proprietorship.

Inventory accounting: must every Sole Proprietorship have primary documents for the entire product range

No. For the purposes of compliance with ECR legislation, there is an important exception.

Sole Proprietorships under the simplified taxation system that are not registered as VAT payers are not required to maintain the Inventory Accounting Form under Order No. 496 unless they sell:

• technically complex household goods subject to warranty repair;

• medicinal products and medical devices;

• jewelry and household items made of precious metals and relevant precious or semi-precious stones.

For Sole Proprietorships to which Procedure No. 496 applies, the receipt and disposal of goods must be recorded in the Inventory Accounting Form on the basis of primary documents. During an inspection, documents confirming the accounting and origin of inventory at the place of sale must be available.

For a remote business, it is also important to distinguish between:

• a warehouse or storage location;

• a store;

• a fulfillment operator;

• internal movement of goods;

• transfer to the carrier;

• customer returns.

The documentation must correspond to the actual movement of goods.

UAH 1 million threshold and mandatory VAT registration

The rule on mandatory VAT registration is often incorrectly applied to Sole Proprietorships.

Paragraph 181.1 of the Tax Code provides for mandatory registration if the total amount of taxable transactions involving the supply of goods or services over the previous 12 calendar months exceeds UAH 1,000,000 excluding VAT.

However, single tax payers in groups one through three are expressly excluded from this rule.

Therefore, a Sole Proprietorship in the second or third single tax group is not required to register as a VAT payer solely because its turnover exceeds UAH 1 million.

In addition, for the general taxation system and other persons to whom the rule applies, the calculation is based not on all funds credited to the account or income for the calendar year, but on the amount of the relevant supply transactions during the previous 12 calendar months.

What penalties apply for violations of ECR/PECR rules

For violations defined in paragraph 1 of Article 17 of Law No. 265, including failure to process a settlement transaction through an ECR/PECR for the full amount or failure to provide the relevant settlement document, the standard financial penalties apply:

The reduced transitional penalties ended on July 31, 2025.

The State Tax Service also explains that each sale made without a proper fiscal document may be treated as a separate violation rather than as one continuing violation covering the entire period.

Practical example: the manager is abroad while a document is executed in Ukraine

In its announcement about automated exchange with the State Border Guard Service, the State Tax Service itself gave an example of how border-crossing information may be used: identifying situations where financial and business documents or company reports are signed by a manager who was outside Ukraine on the date of signing.

The mere fact that a manager is abroad does not prove that a document is fictitious: electronic documents may be signed remotely, and goods may be accepted by an authorized employee. However, the content of the document must correspond to the actual circumstances.

If a document states that a specific person personally accepted goods, carried out a physical inspection, or performed another action at a particular location in Ukraine, while other official data shows that the person was abroad, the enterprise should have documents explaining the actual organization of the transaction.

What a Sole Proprietorship managing a business from abroad should check

1. Whether information on all actual business units has been submitted through Form No. 20-OPP.

2. Whether each PECR is registered to the correct business unit.

3. Whether the certificates of all actual cashiers are registered through Form No. 5-PECR.

4. Whether an employee is using the entrepreneur’s personal qualified electronic signature.

5. Whether persons who actually work in the store on a regular basis have been duly formalized.

6. Whether agreements are in place with fulfillment providers, warehouses, couriers, and other contractors where such work is performed by persons who are not employees of the Sole Proprietorship.

7. Whether the fiscalization method corresponds to the actual payment method: card, acquiring, IBAN, cash on delivery.

8. Whether sales, PECR receipts, consignment notes, returns, and bank receipts are consistent with one another.

9. Whether inventory accounting is maintained under Order No. 496 if the Sole Proprietorship belongs to a category for which such accounting is mandatory.

10. Whether the UAH 1 million threshold is incorrectly used as a VAT criterion for a Sole Proprietorship in single tax groups one through three, to which this rule does not apply.

PECR, Ukrposhta and bank statements in Torgsoft: control of sales, delivery and payment

Torgsoft provides separate tools for building such an accounting chain. The additional feature «Integration with Ukrposhta» allows consignment notes to be created from a sales invoice, shipping labels to be printed, and parcel status to be tracked directly from Torgsoft. This makes it possible to link a warehouse sale to a specific postal shipment and monitor its movement.

The software also supports PECR operations: registration and addition of a software ECR, linking it to a business unit, working with cashiers, and issuing and sending fiscal receipts. This makes it possible to organize sales so that a transaction in the accounting system is linked to the relevant PECR and the cashier works within the configured permissions.

A separate «Bank statements» section makes it possible to reconcile bank transactions with Torgsoft financial documents. For PrivatBank accounts, Torgsoft can create a payment order and transfer it to the online banking system for signature by the account owner without giving other employees access to the personal banking account. After completed banking transactions are received in the statement, the corresponding financial documents can be generated in Torgsoft.

For a remote owner, this model makes it possible to compare four main stages of one transaction: the sale of goods, the fiscal receipt, the postal shipment, and the actual receipt of funds. This does not replace proper legal formalization of employees, agreements, and primary documents, but it significantly simplifies internal control over whether accounting data corresponds to actual transactions.

Official sources

1. Tax Code of Ukraine No. 2755-VI — subpara. 14.1.213 on tax residency; para. 63.3 on taxable objects; Articles 181 and 183 on VAT.
Tax Code of Ukraine No. 2755-VI

2. Law of Ukraine No. 265/95-VR «On the Use of Registrars of Settlement Transactions in Trade, Public Catering and Services» — Art. 2, Art. 3, Art. 9, Art. 17.
Law No. 265/95-VR on ECR/PECR

3. Order of the Ministry of Finance of Ukraine dated 23.06.2020 No. 317 — Procedure for registration and use of PECRs, Forms No. 1-PECR and No. 5-PECR.
Ministry of Finance Order No. 317

4. Order of the Ministry of Finance of Ukraine dated 21.01.2016 No. 13 — form and mandatory details of settlement documents.
Ministry of Finance Order No. 13

5. Order of the Ministry of Finance of Ukraine dated 03.09.2021 No. 496 — Procedure for maintaining inventory records by Sole Proprietorships.
Ministry of Finance Order No. 496

6. Labor Code of Ukraine — Art. 24 regarding formalization of an employee before actual admission to work.
Labor Code of Ukraine

7. Law of Ukraine No. 2155-VIII «On Electronic Identification and Electronic Trust Services» — requirements regarding confidentiality and control of the private key.
Law No. 2155-VIII

8. Law of Ukraine No. 361-IX «On Prevention and Counteraction to Legalization (Laundering) of Proceeds…» — Articles 8 and 11 regarding due diligence and monitoring of customer transactions.
Law No. 361-IX on financial monitoring

9. Resolution of the Board of the NBU dated 24.02.2022 No. 18 — para. 5-2 and para. 14 regarding the use of corporate payment instruments and currency restrictions. The current version takes into account NBU Resolution No. 90 dated 10.08.2026.
NBU Resolution No. 18
NBU Resolution No. 90 dated 10.08.2026

10. Resolution of the Board of the NBU dated 26.02.2026 No. 20 — changes to the requirements for payment instructions when transferring funds without opening an account.
NBU explanation regarding Resolution No. 20

11. State Tax Service of Ukraine, 03.08.2026 — «State Tax Service and State Border Guard Service improve electronic information exchange».
Official announcement of the State Tax Service

12. State Tax Service — explanation regarding ECR/PECR use in online trade and cash on delivery.
State Tax Service explanation regarding cash on delivery for an online store

13. Ukrposhta — official announcements on changes to payment transactions and taxpayer identification numbers in August 2026.
Official Ukrposhta news

14. National Bank of Ukraine — termination of the regulatory UAH 150,000 limit on P2P transfers by individuals from April 1, 2025.
Official NBU announcement