Limits for individual entrepreneurs, financial monitoring and reporting in August 2026

Bank Transfer Limits for Sole Proprietorships, Financial Monitoring, and Consolidated Reporting in 2026: What Changes in August

Social media posts are circulating about new bank limits for Sole Proprietorships and changes to the rules for submitting consolidated reports. In fact, these are two separate changes that apply to different categories of entrepreneurs.

No nationwide transaction limit for all Sole Proprietorships will be introduced on August 14, 2026. The updated banking market Memorandum provides that three months after a particular bank signs the amendments, monthly limits may be applied to newly established and inactive high-risk Sole Proprietorships: up to UAH 600,000 for Group 1 and up to UAH 3,000,000 for Groups 2 and 3. After six months, these amounts may be reduced to UAH 400,000 and UAH 1,000,000 respectively. For institutions that signed the amendments on May 14, 2026, the indicative dates are August 14 and November 14. An entrepreneur may provide the bank with documents confirming the economic purpose and required volume of transactions, but the bank makes the final decision on the limit.

Separately, on August 1, 2026, the new quarterly Tax Calculation form begins to apply to Sole Proprietorships and individuals engaged in independent professional activity who are required to submit this Calculation. Reports for the second quarter must be submitted by August 10. If monthly Calculations for April, May, and June have already been submitted, there is no need to resubmit the quarterly form. If reports were not submitted for all months, the quarterly Calculation should include data only for the missing months.

Why Bank Limits Are Not a New Legal Requirement

On May 14, 2026, banking market participants signed amendments to the Memorandum on Ensuring Transparency in the Payment Services Market. The document coordinates the approaches used by banks and other payment service providers when working with high-risk clients.

The Memorandum:

• is not a law of Ukraine;

• is not a resolution of the National Bank of Ukraine;

• does not amend Law No. 361-IX on financial monitoring;

• does not establish tax rules for Sole Proprietorships;

• is applied by banks and other payment service providers that have joined it;

• is implemented through the internal risk-based procedures of each financial institution.

The Association of Ukrainian Banks explicitly states that the Memorandum does not create new legislative restrictions but coordinates market practices. Each bank continues to independently assess the client’s risk, activities, sources of funds, and whether actual transactions correspond to the declared business model.

What Limits Are Provided for High-Risk Sole Proprietorships

The phased limits apply to high-risk clients, especially newly established and inactive Sole Proprietorships that are resuming their activities.

For institutions that signed the document on May 14, 2026, the first stage begins on August 14 and the second — on November 14, 2026. If an institution joined later, you should check the notifications and service terms of your particular bank.

The monthly volume may include transfers in hryvnias and foreign currencies from all client accounts opened with the relevant payment service provider in favor of other counterparties. Each institution independently determines whether particular transactions, such as tax or utility payments, should be excluded from this calculation.

When a Bank May Not Apply the Standard Limit

The Memorandum provides that standard restrictions should not be applied equally to all entrepreneurs. An exception may be made for clients who:

• conduct lawful and transparent business activities;

• pay taxes on time and in full;

• officially employ their staff;

• have documented sources of income;

• conduct transactions that correspond to their registered types of activity;

• can provide documentary explanations regarding their counterparties, payment purposes, and turnover.

If the established level does not correspond to the actual needs of the business, a Sole Proprietorship may apply to the bank for an increase. The Memorandum explicitly allows larger amounts to be substantiated by seasonal business activity, capital expenditure, planned purchases, and other economically justified needs. The bank makes the final decision based on its assessment of the documents and risk.

Will Sole Proprietorships Really Be Allowed to Have Only Three Accounts?

There is no general legislative prohibition against having more than three bank accounts. The Tax Code, Law No. 361-IX, and regulations of the National Bank do not establish a single restriction of «three accounts in total» for all entrepreneurs.

At the same time, the updated Memorandum contains a separate rule for clients without documented sources of income: they may have no more than three current accounts in one currency. The following are excluded from this restriction:

• deposit accounts;

• credit accounts;

• accounts opened for participation in government support programs.

Therefore, this is neither a legislative prohibition nor a limit of three accounts across all banks combined. It is an agreed banking approach applied by signatories to the Memorandum to clients who do not have sufficient documentary proof of income. The specific procedure depends on the institution’s internal rules.

How Financial Monitoring Applies to Sole Proprietorships

A bank is a primary financial monitoring entity. It is required to:

• identify and verify the client;

• establish the purpose and nature of the business relationship;

• assess the level of risk;

• establish the source of funds in cases provided for by law;

• compare actual transactions with information about the client’s activities;

• identify threshold and suspicious financial transactions;

• regularly update client information.

If turnover significantly exceeds the amount declared by the Sole Proprietorship when opening the account, the bank may request explanations and documents. An additional review is also possible when payment purposes, the number of counterparties, the geography of transactions, or the nature of incoming funds do not correspond to the declared type of business.

Law No. 361-IX allows a bank to refuse to process a transaction or continue a business relationship if it is impossible to conduct proper client due diligence, establish the required information, or the risk is considered unacceptably high. This does not mean that every large transaction is automatically blocked: the decision must be based on an assessment of the specific client and transaction.

What the Amount of UAH 400,000 Means

The amount of UAH 400,000 in Law No. 361-IX — is not a general transfer limit or a threshold below which the bank does not review transactions.

A financial transaction equal to or exceeding UAH 400,000 is considered a threshold transaction only if it has one or more of the characteristics specified in Article 20 of the Law. At the same time, a transaction may be considered suspicious regardless of its amount if the bank has grounds to believe that it is related to money laundering, terrorist financing, circumvention of restrictions, or does not correspond to the client’s known activities.

Therefore, splitting one payment into several smaller payments does not eliminate financial monitoring. The bank may assess related transactions collectively.

What Documents Should Be Prepared for the Bank

The law does not establish a single universal package of documents. The list depends on the nature of the transaction, the type of business, and the bank’s request.

The following documents may be required to confirm business activities:

Documents Confirming Sales and Provision of Services

• contracts with buyers and customers;

• invoices;

• certificates of completed work or services rendered;

• sales invoices;

• goods transport notes;

• customer orders;

• fiscal receipts issued through an ECR or РECR;

• delivery service documents;

• reports from marketplaces and payment services.

Documents Confirming the Origin of Goods and Expenses

• contracts with suppliers;

• goods receipt and sales invoices;

• supplier invoices;

• acceptance and transfer certificates;

• customs declarations;

• transportation documents;

• documents confirming the rental of premises, equipment, or a warehouse;

• documents confirming the purchase of fixed assets.

Tax and Employment Documents

• tax returns;

• receipts confirming the acceptance of reports;

• confirmation of tax and Unified Social Contribution payments;

• employment contracts or employee appointment orders;

• payroll and salary payment records;

• contracts with individuals who perform work or provide services;

• submitted Tax Calculations.

Explanation of a Specific Transaction

The explanation should specify:

• who the counterparty is;

• what exactly is being purchased or sold;

• why the transaction amount corresponds to the scale of the business;

• the source from which the funds were received;

• whether the payment relates to a seasonal purchase, store expansion, or equipment acquisition;

• the period over which the amount was accumulated;

• which primary documents confirm the transaction.

The documents must be consistent with one another. The amounts in the contract, invoice, goods invoice, bank payment, and accounting records must not contradict one another without a proper explanation.

How to Reduce the Risk of Payments Being Suspended

Entrepreneurs should follow several rules:

1. Use a business account for business transactions. An individual’s personal cards should not be used systematically to accept payments for goods or services.

2. Keep information held by the bank up to date. If the type of activity has changed, the number of stores has increased, employees have been hired, imports or wholesale buyers have appeared, or seasonal turnover has increased, this information should be provided to the bank before payments rise sharply.

3. Specify the payment purpose correctly. It should make it clear what the funds are being transferred for and correspond to the contract, invoice, or other document.

4. Retain primary documents. The bank may ask for confirmation of both the receipt and subsequent use of funds.

5. Do not artificially split transactions. A series of related payments may be assessed as a single transaction scheme.

6. Arrange an increase in the limit in advance. If a major purchase or seasonal growth in turnover is planned, it is better to provide the bank with the documents before making the payments.

7. Maintain tax compliance. Timely reporting, tax payments, officially employed staff, and turnover consistent with tax returns reduce the number of additional questions.

Consolidated Reporting for Sole Proprietorships: What Changes on August 1

This concerns the Tax Calculation of income accrued or paid to individuals, amounts of tax withheld, military levy, and accrued Unified Social Contribution.

For Sole Proprietorships and individuals engaged in independent professional activity, the reporting period is quarterly. In the new form, the figures are divided by each month of the quarter.

Other tax agents, including legal entities, will continue to report monthly. The new monthly forms will first apply to July 2026.

Who Must Submit the Quarterly Calculation

The obligation arises for a Sole Proprietorship or independent professional if, during the reporting period, they accrued or paid income to individuals as a tax agent or Unified Social Contribution payer, including:

• employee salaries;

• payments under civil law contracts;

• rent paid to an individual;

• other income that must be included in the Tax Calculation;

• payments for which Unified Social Contribution information must be submitted.

The State Tax Service states that the Tax Calculation is submitted only if income that must be included in the reports was accrued or paid to individuals.

How to Report for the Second Quarter of 2026

Until August 1, electronic systems accepted the monthly form. The State Tax Service confirmed that reports for April, May, and June submitted using the previous form will be accepted and processed.

The deadline for submitting the quarterly Calculation for the second quarter is August 10, 2026. The general deadline is 40 calendar days after the end of the quarter, and when the final day falls on a weekend, the deadline is moved to the next business day.

Penalties for Failure to Submit Reports or for Reporting Errors

Paragraph 119.1 of the Tax Code provides for a fine of UAH 1,020 for:

• failure to submit the Tax Calculation;

• submission after the established deadline;

• incomplete submission;

• inaccurate information or errors that resulted in changes to tax liabilities or the taxpayer.

If the same violation is repeated within one year after the fine was imposed, the amount is UAH 2,040. The Tax Code also provides for cases in which no penalty is imposed for inaccurate information, including certain self-corrections expressly provided for by law.

Failure to pay or late payment of personal income tax, military levy, or Unified Social Contribution has separate consequences. The extent of liability depends on the type of payment, the period of delay, the circumstances of the violation, and the applicable special rules.

What the Banking Memorandum and New Reporting Form Do Not Change

The changes discussed do not establish new requirements concerning:

• registration of a Sole Proprietorship;

• selection or change of a single tax group;

• annual income limits for remaining within the simplified taxation system;

• mandatory licensing;

• ECR or РECR;

• the format of a fiscal receipt;

• product labelling;

• product storage;

• requirements for retail and warehouse premises;

• delivery;

• employment registration;

• permits for trading particular categories of goods.

The bank’s monthly limit does not replace the maximum income allowed for the relevant single tax group under Article 291 of the Tax Code. It also does not in itself create an obligation to use an ECR or РECR.

The need for a licence, fiscalization, special labelling, or compliance with specific storage conditions is determined by the type of goods or services and the payment method under the applicable special laws. The ECR Law continues to apply to settlement transactions in trade, catering, and services under the general rules.

Bank Statements, Payment Documents, and Transaction Control in Torgsoft

Torgsoft can be used to maintain product, warehouse, and financial records; register goods receipts, sales, returns, customer payments, settlements with suppliers, cash flow, and bank statements. The bank statement processing option makes it possible to receive account data and match incoming and outgoing payments with invoices, orders, and financial documents. The Torgsoft help system describes support for statements, including statements from Privat24 for business, monobank, and UKRSIBBANK.

To prepare a response to a bank request, an entrepreneur can use data on sales, goods receipt and sales invoices, payments, settlements with business partners, warehouse operations, and financial reports. This helps quickly match the amount of a bank transfer with a specific purchase, sale, or order and identify discrepancies before submitting documents to the financial institution.

Torgsoft also supports integration with a software РECR and bank terminals: the sale, payment method, and fiscal receipt can be linked within a single accounting process. The program helps organize internal control but does not replace properly prepared primary documents, tax reports, or the bank’s decision regarding the sufficiency of the evidence provided.

What Entrepreneurs Need to Do Before August

• Check whether your bank has announced that it has joined the updated Memorandum.

• Clarify the established monthly transaction volume and the procedure for increasing it.

• Update the bank on your types of activity, expected turnover, and sources of funds.

• Prepare contracts, invoices, goods invoices, certificates, tax returns, and employee documents.

• Check whether the monthly Tax Calculations for April, May, and June have been submitted.

• If one or more months were missed, submit a quarterly Calculation from August 1 containing data only for those months.

• Do not duplicate figures already accepted by the State Tax Service.

• Submit the report for the second quarter no later than August 10, 2026.

• Compare bank turnover with tax returns and internal accounting records.

• Do not use personal cards to systematically receive business revenue.

Official Sources

1. Law of Ukraine «On Prevention and Counteraction to Legalization (Laundering) of the Proceeds of Crime, Terrorist Financing and Financing the Proliferation of Weapons of Mass Destruction» dated December 6, 2019, No. 361-IX — Articles 11, 12, 15, 20, and 21:
   https://zakon.rada.gov.ua/laws/show/361-20#Text

2. Regulation on Financial Monitoring by Banks, approved by Resolution of the Board of the National Bank of Ukraine dated May 19, 2020, No. 65:
   https://zakon.rada.gov.ua/laws/show/v0065500-20#Text

3. Updated Memorandum on Ensuring Transparency in the Payment Services Market dated May 14, 2026 — rules concerning accounts, risk-based control, and transfers by Sole Proprietorships:
   https://aub.org.ua/wp-content/uploads/2026/05/memorandum.pdf

4. Announcement by the Association of Ukrainian Banks on the Signing of the Updated Memorandum:
   https://aub.org.ua/novi-limity-na-perekazy-dlya-fop-i-kompanij-banky-pidpysaly-onovlenyj-memorandum/

5. Tax Code of Ukraine dated December 2, 2010, No. 2755-VI — Articles 46, 49, 51, 119, 176, and 291:
   https://zakon.rada.gov.ua/laws/show/2755-17#Text

6. Order of the Ministry of Finance of Ukraine dated January 13, 2015, No. 4 «On Approval of the Tax Calculation Forms…»:
   https://zakon.rada.gov.ua/laws/show/z0111-15#Text

7. Order of the Ministry of Finance of Ukraine dated May 7, 2026, No. 243, which approved amendments to the Tax Calculation form:
   https://zakon.rada.gov.ua/laws/show/z0751-26#Text

8. Order of the Ministry of Finance of Ukraine dated May 27, 2026, No. 284, which amended Order No. 243:
   https://zakon.rada.gov.ua/laws/show/z0780-26#Text

9. Official clarification by the State Tax Service concerning the use of the new forms and submission of reports for the second quarter of 2026:
   https://tax.gov.ua/media-tsentr/novini/1030419.html

10. Law of Ukraine «On the Use of ECRs in Trade, Catering, and Services» dated July 6, 1995, No. 265/95-VR — Articles 3, 9, and 17:
    https://zakon.rada.gov.ua/laws/show/265/95-%D0%B2%D1%80#Text