Acquiring, NovaPay, and Payment Services: Date and Amount of Sole Proprietor Income Including Commission

When payment is made via a POS terminal or internet acquiring, the income of a Sole Proprietorship is determined based on the full amount paid by the customer, without reducing it by the bank commission. If a fiscal receipt is issued for UAH 1,000 and UAH 980 is credited to the account after the commission is deducted, the income is UAH 1,000. The income date is the date specified in the fiscal receipt, even if the bank transfers the funds later.

For cash on delivery via NovaPay, a different rule applies: the income date for a Sole Proprietorship under the single tax system is the date when the funds are credited to the business account, not the date when the goods are shipped or the receipt marked «cash on delivery» is issued. For a direct transfer to an IBAN account, income is also recognized on the date the funds are credited. The payment service commission does not reduce the income of a single tax payer, while a Sole Proprietorship under the general taxation system may include a documented commission in expenses if it is directly related to business activities.

Income date and amount depending on the payment method

The name of the payment service itself does not determine the taxation procedure. It is important to establish what type of transaction actually takes place: acquiring, a regular bank transfer, a transfer through a payment institution, cash on delivery, a cash payment, or performance under an agency agreement.

The acquiring rules are confirmed by the current response in the Public Information and Reference Resource of the State Tax Service of Ukraine. For direct transfers to an IBAN, the State Tax Service separately states that an ECR/РECR is not required when the customer independently transfers funds using the full details of the entrepreneur’s current account.

Acquiring: why income is the amount before commission deduction

Acquiring consists of two separate business transactions:

1. The Sole Proprietorship sells goods to the customer or provides a service.

2. The bank or payment service provides the Sole Proprietorship with a payment acceptance and transfer service.

If the customer pays UAH 5,000, the full UAH 5,000 is sales revenue. The UAH 100 withheld by the bank is not a discount for the customer and does not change the price of the goods. It is the entrepreneur’s fee for the acquiring service.

Example

On July 22, a customer paid by card for goods worth UAH 10,000. The РECR issued a receipt for UAH 10,000. The bank withheld a UAH 200 commission and transferred UAH 9,800 to the Sole Proprietorship account on July 23.

For a Sole Proprietorship under the single tax system:

• income — UAH 10,000;

• income date — July 22;

• the UAH 200 commission does not reduce the single tax base;

• UAH 10,000 is included in the annual income limit.

For a Sole Proprietorship under the general taxation system:

• gross income — UAH 10,000;

• income date — July 22;

• UAH 200 may be included in expenses if the appropriate supporting documents are available;

• net taxable income from this transaction will be UAH 9,800 if there are no other adjustments.

For a Sole Proprietorship under the general taxation system, the taxable amount is the difference between all income received and documented expenses related to business activities. Such expenses include, in particular, fees for banking and settlement services if they are directly related to earning business income.

What is the significance of the State Tax Service letter dated 26.02.2026 No. 209/2/99-00-21-01-01-02

The State Tax Service letter dated February 26, 2026 No. 209/2/99-00-21-01-01-02 sets out the position that when payment is made through bank or internet acquiring with the issuance of a fiscal receipt:

• income is the full amount of revenue including the bank commission;

• the income date is the date specified in the fiscal receipt.

This position is based, in particular, on the letter of the Ministry of Finance of Ukraine dated 10.04.2024 No. 11210-04-62/11995 and is reflected in the current Knowledge Base of the State Tax Service.

At the same time, a State Tax Service letter addressed to a government authority or a committee of the Verkhovna Rada does not amend the Tax Code and is not an individual tax consultation for a specific entrepreneur. An individual tax consultation must be provided to the taxpayer upon request and registered in the Unified Register of Individual Tax Consultations. It may be used only by the taxpayer to whom it was issued.

NovaPay and cash on delivery: the receipt date is not always the income date

Cash on delivery via NovaPay cannot automatically be treated as bank acquiring.

The State Tax Service considered a situation where:

• the goods were shipped on December 31;

• the seller issued a fiscal receipt with the payment type «cash on delivery»;

• NovaPay credited the funds to the entrepreneur’s account on January 2 of the following year.

In this case, the income date for a Sole Proprietorship under the single tax system is January 2 — the date the funds are credited to the account. The amount does not become income of the previous year solely because the receipt or invoice was issued on December 31.

What amount should be reported if NovaPay withholds a commission

The NovaPay agreement and transaction register must be checked.

If the documents confirm that:

• the customer paid UAH 1,000 for the goods;

• UAH 20 was withheld as a separate payment service commission;

• UAH 980 was transferred to the seller,

then the sales revenue is UAH 1,000, while UAH 20 is a separate fee for the transfer service.

For a single tax payer, income will be UAH 1,000 because expenses do not reduce the single tax base. For a Sole Proprietorship under the general taxation system, UAH 20 may be treated as a documented business expense.

The entrepreneur must have documents that separately identify:

• the value of the goods sold;

• the amount received from the customer;

• the commission amount;

• the amount actually transferred to the Sole Proprietorship;

• the date the funds were credited.

If the payment service report does not allow the customer payment to be separated from the commission, a bank statement showing only UAH 980 is not sufficient to reliably substantiate the transaction.

Who must issue the receipt for cash on delivery

The seller’s obligation to use an ECR/РECR depends not only on the term «cash on delivery», but also on the terms of the agreements between the seller, carrier, freight forwarder, courier, and payment institution.

There are two main models.

The logistics company only delivers the goods

If the delivery service:

• is not a party to the purchase and sale transaction;

• does not transfer the goods on its own behalf;

• does not accept payment as the seller’s courier;

• does not process payment for the goods,

the seller must issue its own fiscal receipt in accordance with the actual sales model and provide it to the customer. In its explanations, the State Tax Service states that under such a model, the receipt must be issued before the goods are handed over to the logistics company or sent to the customer before or at the time of such handover.

The courier or carrier accepts cash on delivery on its own behalf

If the agreement expressly provides that the courier:

• accepts funds directly from the customer;

• issues a settlement document to the customer;

• participates in the payment transaction when the goods are handed over,

the State Tax Service allows a model in which the seller does not issue another fiscal receipt for the same transaction. In this case, a delivery note or another document confirming the origin and sale of the goods is enclosed with the shipment and, where required, a warranty certificate, technical passport, or other accompanying documents.

Because contractual models differ, it is not sufficient to rely solely on the «NovaPay» designation in the statement. It is necessary to check:

• who accepts payment from the customer under the agreement;

• on whose behalf the receipt is issued;

• who transfers the goods and ownership rights;

• whether the carrier participates in the payment transaction;

• what document the customer receives;

• what document confirms the sale specifically by the Sole Proprietorship.

For a non-standard arrangement, a safer approach is to obtain an individual tax consultation and provide the agreements, cash flow scheme, and sample documents.

LiqPay, WayForPay, and other payment services

LiqPay, WayForPay, Fondy, Portmone, and other services may operate under different types of agreements. A single service may provide internet acquiring, payment initiation, transfer without opening an account, or technical payment processing.

If the agreement provides for internet acquiring with card payment and issuance of a fiscal receipt, the acquiring rule applies:

• income — the full amount before commission;

• income date — the date of the fiscal receipt;

• ECR/РECR — required unless a specific exemption applies.

If the customer is provided with full IBAN details and independently makes a regular account-to-account transfer without acquiring, the income date is the date the funds are credited, and an ECR/РECR is not used for such payment.

In a fiscal receipt, the payment form and the actual payment method are specified separately. For card and online payments, the payment form is indicated as non-cash, while the payment method may be «merchant acquiring», «internet acquiring», «online card payment», «LiqPay», «NovaPay», or another designation corresponding to the actual transaction. For combined payments, the relevant lines are repeated for each payment form and method.

Direct transfer to an IBAN

An ECR/РECR is not required if the seller provides the customer with the full details of their current account in IBAN format and the customer independently makes a bank transfer:

• from their current account;

• via online banking;

• through a bank cash desk;

• through a bank payment terminal or a self-service payment terminal owned by a bank.

Such a transaction is treated as a banking transaction rather than a settlement transaction within the meaning of the ECR Law. Income arises on the date the funds are credited to the Sole Proprietorship account.

A payment link, an «Pay by card» button, an acquiring QR code, or a form for entering payment card details does not become an IBAN transfer merely because the funds are ultimately credited to the business account. In such cases, the payment instrument and the agreement with the service provider must be analyzed.

Agency and commission agreements

Paragraph 292.4 of the Tax Code establishes a special rule for mandate agreements, commission agreements, freight forwarding agreements, and agency agreements: the income of a single tax payer is the remuneration of the attorney, commission agent, freight forwarder, or agent.

This rule applies only if there is a genuine intermediary agreement and the entrepreneur actually performs intermediary functions. An ordinary seller of their own goods cannot call a bank or payment commission an «agency scheme» in order to include only the difference in income.

If an agent receives UAH 10,000 from the customer, of which UAH 1,000 is the agent’s remuneration:

• income for single tax purposes is UAH 1,000;

• the entire amount received from the customer — UAH 10,000 — is processed through the ECR/РECR;

• the agreement, agent’s report, and remuneration calculation must be retained together with the payment documents.

Single tax: commission does not reduce the tax base or annual limit

A single tax payer does not determine taxable profit as the difference between income and expenses. Therefore, a bank, NovaPay, or other service commission is not deducted from income, even if the entrepreneur actually receives a smaller amount in their account.

The full amount of acquiring sales is taken into account:

• in income reported in the tax return;

• when determining the single tax for Group 3;

• when determining the military levy for Group 3;

• when monitoring the annual income limit;

• when assessing eligibility to remain in the relevant group.

In 2026, the annual income limits are:

The limits are calculated based on the minimum wage of UAH 8,647 established as of January 1, 2026.

If РECR data shows sales of UAH 7,200,000, while UAH 7,060,000 is credited to the bank account after commissions, UAH 7,200,000 is used for monitoring the limit rather than the amount of bank credits.

General taxation system: commission may be included in expenses

For a Sole Proprietorship under the general taxation system:

• the full revenue before commission deduction is included in income;

• the commission is accounted for separately as an expense;

• the expense must be related to business activities;

• the expense must actually be incurred and supported by documents.

To substantiate the commission, it is advisable to retain:

• the acquiring agreement or agreement with the payment institution;

• bank statements;

• transaction registers;

• service acceptance certificates;

• invoices or commission reports;

• payment instructions;

• documents that allow the commission to be linked to specific sales.

Subparagraph 177.4.4 of the Tax Code allows fees for banking and settlement services directly related to business activities to be included in expenses.

ECR/РECR: key requirements

When carrying out settlement transactions, a Sole Proprietorship must:

• process the transaction through a registered ECR or РECR for the full purchase amount;

• issue a fiscal receipt in the prescribed form;

• provide the receipt to the customer in paper or electronic form;

• correctly specify the payment form and payment method;

• not disguise a card payment as an IBAN transfer;

• not postpone issuing the receipt until the date of the bank credit;

• open and close shifts and generate daily reports where required;

• ensure that cashiers work using registered electronic signatures.

Before starting to use a РECR, it is necessary, in particular, to:

1. Notify the State Tax Service of the business facility using Form No. 20-OPP.

2. Submit an application using Form No. 1-РECR.

3. Submit information about cashiers’ electronic signatures using Form No. 5-РECR.

4. Obtain a fiscal number for the РECR.

5. Configure the product list, tax groups, payment forms, and payment methods.

Group 1 Sole Proprietorships may be exempt from using an ECR/РECR if they comply with the requirements of their group. For other entrepreneurs, the main exemption applies when payment is received exclusively as a regular bank transfer using IBAN details.

Documents confirming income and commission

A separate set of supporting documents should be prepared for each payment channel.

For a POS terminal

• acquiring agreement;

• fiscal receipt;

• payment terminal receipt or terminal data;

• register of acquiring transactions;

• bank statement;

• document confirming the commission amount.

For internet acquiring

• agreement with the service provider;

• confirmation of successful payment;

• fiscal receipt;

• transaction report or register;

• bank statement;

• commission statement or report;

• order and customer delivery data.

For NovaPay and cash on delivery

• agreement with the payment institution and delivery service;

• express consignment note or consignment note;

• fiscal document issued by the party that accepted payment;

• delivery note or another document for the goods;

• cash-on-delivery register;

• report on the commission withheld;

• bank statement;

• return document if the customer did not receive the goods.

For an IBAN transfer

• invoice or another document containing payment details;

• bank statement;

• payment instruction, if available;

• agreement, order, delivery note, or act;

• document confirming the transfer of goods or provision of services.

The documents must make it possible to reconcile a single transaction across all systems: order, sale, fiscal receipt, payment, commission, bank credit, delivery, and return.

Marketplaces and offsetting commissions

Not every automatic commission deduction is ordinary acquiring.

With bank acquiring, the customer pays the seller the full monetary amount, while the bank separately withholds a fee for its service. The State Tax Service expressly allows the full amount to be included in income without treating the bank commission as a non-monetary settlement.

A different situation may arise when a marketplace:

• maintains an internal seller balance;

• charges its own commissions and advertising fees;

• settles them by offsetting mutual obligations;

• transfers only the remaining balance to the seller;

• does not make a separate monetary payment of the commission.

The State Tax Service letter dated 26.02.2026 No. 209/2/99-00-21-01-01-02 sets out a strict approach to certain marketplace transactions: automatic settlement of commissions using the seller’s funds may be assessed differently from bank acquiring. This conclusion should not be directly applied to every Sole Proprietorship and every service, but it confirms the need to analyze the agreement, the payment flow, and the method by which monetary obligations are discharged.

For single tax payers, the risk lies in the prohibition on non-monetary forms of settlement. Barter or offsetting may become grounds for mandatory transition to another taxation system in accordance with paragraph 291.6 and subparagraph 4 of subparagraph 298.2.3 of the Tax Code.

License for accepting payments

A Sole Proprietorship seller does not need a separate license merely to accept payment for its own goods or services through a bank or payment institution.

The provider of financial payment services must hold the required license and authorization. The law allows a payment institution to provide financial payment services if it has the relevant authorization and is included in the Payment Infrastructure Register of the National Bank of Ukraine. Before concluding an agreement, the entrepreneur can check the service in this register.

NovaPay is included in the Payment Infrastructure Register as a funds transfer system operated by NovaPay LLC.

Accounting for acquiring, bank commissions, and NovaPay cash on delivery in Torgsoft

In Torgsoft, sales revenue and payment acceptance costs can be accounted for separately. Financial analysis includes the items «Sales Revenue», «Bank Commission», and «Acquiring». Money received from sales is recorded as sales revenue, while commission for card payments is recorded as a separate acquiring expense. This makes it possible to avoid reducing the sales amount to the net bank credit and to monitor the actual cost of payment processing.

In the «Payment — Bank Account Statements» section, you can retrieve and review account transactions. The statement shows the transaction date and time, credit or debit amount, currency, transaction type, sender, recipient, and payment description. This makes it possible to reconcile fiscal receipts with bank credits, identify withheld commissions, and monitor payments received with a delay.

For Nova Poshta shipments in Torgsoft, the «Payment Control» setting is available. If there is an agreement with Nova Poshta, the invoice amount is automatically transferred to the corresponding consignment note field. If a delivery note is marked as cash on delivery and an unpaid balance remains, the program activates «Payment Control» or cash on delivery. If the invoice has already been paid in full, the user receives a warning, helping prevent the customer from being charged twice.

For tax reconciliation, it is advisable to generate separate totals for:

• cash;

• POS acquiring;

• internet acquiring;

• IBAN transfers;

• NovaPay and other cash-on-delivery payments;

• bank commissions;

• customer refunds;

• unpaid and partially paid sales.

Main tax and cash register risks

Reporting only the net bank credit

If acquiring receipts show sales of UAH 1,000,000 and the bank transfers UAH 980,000 after commissions, income is UAH 1,000,000. Reporting only UAH 980,000 understates income by UAH 20,000.

Using the bank statement date for acquiring

For acquiring, the income date is the date of the fiscal receipt. Moving the income to the date of the bank credit may distort monthly, quarterly, or annual accounting and affect the calculation of the single tax income limit.

Using the receipt date for NovaPay cash on delivery

For cash on delivery, the income date for a Sole Proprietorship under the single tax system is the date the funds are credited. Issuing a receipt on December 31 does not make the amount income of that year if the funds are received on January 2.

Incorrect payment method designation

The receipt must reflect the actual transaction. A card payment should not be designated as a regular account transfer, and cash on delivery should not be designated as cash received if the Sole Proprietorship did not actually receive cash.

Late issuance of a fiscal receipt

Tax accounting of income and compliance with ECR requirements are separate obligations. Even if the amount is correctly included in the tax return, late issuance or failure to provide a fiscal receipt may constitute a separate violation.

Absence of an agreement and commission register

Without supporting documents, it is impossible to reliably prove that the difference between the sales amount and the bank credit is a commission rather than a discount, refund, partial payment, or another transaction.

Penalties for ECR/РECR violations

Financial penalties apply when a settlement transaction is carried out without an ECR/РECR, for an incomplete amount, or without issuing the required settlement document:

• 100% of the value of goods, works, or services — for the first violation;

• 150% of the value — for each subsequent violation.

The reduced penalties of 25% and 50%, which temporarily applied to some Sole Proprietorships, ceased to apply on August 1, 2025. Each sale without a proper receipt may be treated as a separate violation.

Understatement of income may also result in additional tax and military levy assessments, penalties, and late-payment interest. For a single tax payer, additional risks include exceeding the annual income limit or using a prohibited non-monetary form of settlement.

Payment accounting algorithm

1. Determine the legal model of the payment: acquiring, IBAN, cash on delivery, transfer through a payment institution, or agency settlement.

2. Determine the full amount paid by the customer.

3. Determine the bank or payment service commission separately.

4. Check who must issue the fiscal receipt.

5. Specify the actual payment form and payment method in the receipt.

6. Determine the income date:

   • for acquiring — the date of the fiscal receipt;

   • for NovaPay cash on delivery — the date the funds are credited;

   • for IBAN — the date the funds are credited;

   • for cash — the date the cash is received.

7. Record the full amount of income without reducing it by the commission.

8. Under the general taxation system, separately include the documented commission in expenses.

9. Reconcile the order, receipt, bank statement, service register, and delivery documents.

10. Check accumulated income against the annual single tax limit.

Official sources

1. Tax Code of Ukraine dated 02.12.2010 No. 2755-VI — paragraphs 291.4, 291.6, 292.1, 292.4, 292.6, 296.1, 296.10, subparagraph 298.2.3, paragraphs 177.2, 177.4, Articles 52–53:
   https://zakon.rada.gov.ua/laws/show/2755-17#Text

2. Law of Ukraine «On the Use of Registrars of Settlement Transactions in Trade, Catering and Services» dated 06.07.1995 No. 265/95-VR — Articles 2, 3, 9, 17:
   https://zakon.rada.gov.ua/laws/show/265/95-%D0%B2%D1%80#Text

3. Regulation on the Form and Content of Settlement Documents approved by Order of the Ministry of Finance of Ukraine dated 21.01.2016 No. 13 — Section II, Form No. FKCh-1:
   https://zakon.rada.gov.ua/laws/show/z0220-16#Text

4. Order of the Ministry of Finance of Ukraine dated 14.06.2016 No. 547 — procedures for registration and use of ECR/РECR:
   https://zakon.rada.gov.ua/laws/show/z0918-16#Text

5. Law of Ukraine «On Payment Services» dated 30.06.2021 No. 1591-IX — authorization of payment service providers and the Payment Infrastructure Register:
   https://zakon.rada.gov.ua/laws/show/1591-20#Text

6. Law of Ukraine «On the State Budget of Ukraine for 2026» dated 03.12.2025 No. 4695-IX — Articles 7–8:
   https://zakon.rada.gov.ua/laws/show/4695-20#Text

7. State Tax Service Public Information and Reference Resource: income of a Sole Proprietorship under the single tax system from bank and internet acquiring — full amount including commission, date of the fiscal receipt:
   https://zir.tax.gov.ua/main/bz/view/?id=44181&src=ques

8. State Tax Service Public Information and Reference Resource: income date for cash on delivery via NovaPay — date the funds are credited to the account:
   https://zir.tax.gov.ua/main/bz/view/?id=42841&src=ques

9. Payment Infrastructure Register of the National Bank of Ukraine — NovaPay payment system:
   https://bank.gov.ua/ua/payments/payment-systems/fdd33166b6199e2d2e454c9cafdb3c88