FOP Inventory Accounting: Requirements, Rules & Fines

FOP Inventory Accounting: Who is obliged to keep it, how to format it, and what fines apply

Inventory accounting for FOP is not accounting according to the standards for legal entities, but a separate obligation established by the Law on RRO and the Ministry of Finance Order No. 496. The essence of the requirement is simple: an entrepreneur subject to this obligation must maintain the prescribed Form for accounting of inventory, enter the receipt and disposal of goods into it based on primary documents, and sell only those goods reflected in such accounting. During an inspection, documents on the accounting and origin of goods must be at the place of sale or available to be provided to the controlling authority. (Legislation of Ukraine)

Not all FOPs are required to keep such accounting. An exception applies to FOPs — single tax payers who are not VAT payers, but even for them the exemption does not work if they sell technically complex household goods subject to warranty repair, medicines, medical devices, or jewelry and household items made of precious metals and stones. For the sale of goods not accounted for in the prescribed manner, or for failure to provide documents during an inspection, a financial sanction is provided in the amount of the value of such goods at sales prices, but not less than 10 tax-free minimum incomes of citizens. (Legislation of Ukraine)

What exactly is considered inventory accounting

Order No. 496 explicitly defines that the documents confirming the accounting and origin of goods consist of two components:

Primary documents may include a description of stock balances at the beginning of accounting, waybills, transport documents, customs declarations, acts of purchase, fiscal receipts, sales receipts, and other documents that allow identifying the supplier, recipient, date of operation, name, quantity, and value of the goods. (Legislation of Ukraine)

That is, for FOP, inventory accounting is not an abstract "control of balances," but a specific link: there is a record in the Accounting Form and there is a primary document on the basis of which this record was made. Without one of these elements, the accounting is considered risky. It is forbidden to sell goods if there are no primary documents, records in the Form, or both documents and records simultaneously at the place of sale. (Legislation of Ukraine)

Who is obliged to keep inventory accounting

Inventory accounting must be kept by FOPs who conduct settlement operations in the field of trade, public catering, or services and who are subject to paragraph 12 of Article 3 of Law No. 265. In practice, this primarily includes:

Who can not keep inventory accounting under Order No. 496

FOPs — single tax payers who are not registered as VAT payers are not obliged to keep inventory accounting if they do not trade in the above-listed "special" groups of goods. This is exactly the exception from paragraph 12 of Article 3 of Law No. 265 and Article 20 of this Law. (Legislation of Ukraine)

However, this exemption applies precisely to the obligation to maintain the Form of accounting of inventory under Order No. 496. It does not cancel other special rules for specific goods — for example, licensing requirements for pharmacies or licensing rules for the retail trade of alcohol and tobacco products. (Legislation of Ukraine)

How to keep inventory accounting correctly

1. Choose a form of maintenance: paper or electronic

The accounting form can be kept either in paper or electronic form. For the electronic form, the FOP independently chooses the software format and the method of entering information, the main thing is to comply with the requirements of Order No. 496. This means that such accounting can be kept not only "manually," but also in your own accounting system, if it allows you to reproduce the established form and show it during an inspection. (Legislation of Ukraine)

2. Fill in the details of the FOP and the place of accounting

The Accounting Form must indicate the FOP's data: full name, tax number or passport details in cases provided by law, tax address, as well as the name and address of the place of sale or place of storage within which the accounting is kept. If the form is paper, this data must be on the title page. (Legislation of Ukraine)

3. Enter the initial balances

If a FOP has an obligation to keep inventory accounting and already has goods on this date, the first record in the Form should reflect the balances at the beginning of accounting. To do this, the entrepreneur independently draws up a description of balances in free form indicating the names of goods, quantity, and cost. If there are no balances, the first record on balances is not entered. (Legislation of Ukraine)

4. Enter receipts before the start of sale

Order No. 496 requires constantly entering information on the receipt and disposal of goods based on primary documents into the Accounting Form. At the same time, records of the receipt of goods must be entered before the start of their realization. This is one of the key requirements: first the document and record, then the sale. (Legislation of Ukraine)

5. Reflect the disposal of goods where necessary

Column 8 of the Accounting Form reflects the disposal of goods, but not sales via RRO/PRRO. For the purposes of the Order, disposal includes, in particular, sale without the use of RRO/PRRO in cases permitted by law, internal movement between own points of sale or places of storage, destruction or loss of goods, return to the supplier, use for own needs. (Legislation of Ukraine)

6. Keep the form and primary documents at the place of sale

The accounting form and primary documents for goods must be kept at the place of sale until the disposal of the last unit of goods reflected in such documents. Documents must be grouped monthly in the chronological order of their reflection in the Form or filed together with the Form. If the original documents are temporarily absent at the place of sale, during the inspection, copies may be provided with the subsequent presentation of the originals before the end of the inspection, if necessary. (Legislation of Ukraine)

Which documents are suitable for confirming the origin of goods

For inventory accounting, the name of the document itself is not important, but its content. The document must allow establishing who supplied the goods, to whom they were transferred, when the transaction took place, what goods these are, in what quantity, and at what cost. That is why Order No. 496 explicitly names waybills, transport documents, customs declarations, acts of purchase, fiscal receipts, sales receipts, and other similar documents with the necessary details among the permissible documents. (Legislation of Ukraine)

If a FOP has several retail outlets, accounting is kept separately for each place of sale. To move goods between own shops, warehouses, or other business objects, primary documents for internal movement are required. They are an integral part of inventory accounting. (Legislation of Ukraine)

Warehouse, shop, car, courier delivery

Order No. 496 defines the place of sale and the place of storage broadly. It can be not only a stationary shop or warehouse, but also a mobile facility, including a vehicle. This means that for off-site trading, delivery, or trading from a car, the entrepreneur must also organize documents and accounting so that the controlling authority can verify the origin of goods and records in the Form. For the electronic form, it must be visualized in a format suitable for viewing and copying during an inspection. (Legislation of Ukraine)

RRO/PRRO and inventory accounting: how they are connected

Inventory accounting does not replace RRO/PRRO, but exists alongside it. If a FOP is obliged to use RRO or PRRO, they must simultaneously fulfill both the requirements of Law No. 265 regarding settlement documents and the requirements for inventory accounting if they fall into the category of obligated persons. Separately, Law No. 265 requires providing the buyer at their request with a receipt, waybill, or other document confirming the transfer of ownership of the goods for consumer protection purposes. (Legislation of Ukraine)

The practical conclusion here is as follows: the presence of a fiscal receipt does not replace the document on the origin of the goods, and the document on the origin of the goods does not replace the fiscal receipt in cases where the receipt is mandatory. These are different obligations. (Legislation of Ukraine)

Inventory accounting does not cancel tax accounting

FOPs on the general taxation system separately keep records of income and expenses according to a standard form approved by the Ministry of Finance. FOPs — single tax payers of the third group who are VAT payers also keep records of income and expenses according to a standard form. And FOPs — single tax payers of the first and second groups and the third group without VAT keep records in free form through a monthly display of income. This is different from inventory accounting. (lv.tax.gov.ua)

Therefore, the Form of accounting of inventory under Order No. 496 does not replace either tax accounting of income and expenses or the books and forms required by the Tax Code for the relevant taxation system. (Legislation of Ukraine)

Specific goods subject to additional rules

For medicines and pharmacy activities, inventory accounting is only part of the requirements. Retail trade of medicines is carried out under specific licensing conditions approved by CMU Resolution No. 929, which were amended in 2025–2026. If a FOP sells medicines or medical goods, it is necessary to check not only Law No. 265 and Order No. 496, but also specialized licensing conditions. (Legislation of Ukraine)

For alcohol, tobacco products, liquids for electronic cigarettes, and fuel, a separate licensing regime applies under a special law. Therefore, even when the issue concerns precisely inventory accounting, it is not enough for businesses with such goods to have only an accounting form and primary documents — it is necessary to separately control licenses and other specialized circulation rules.

What liability threatens

The main sanction precisely for violating the rules of inventory accounting is provided by Article 20 of Law No. 265. It applies in two situations:

The size of the sanction is the value of such goods at sales prices, but not less than 10 tax-free minimum incomes of citizens. For FOP single taxpayers without VAT, this sanction is not applied if they do not trade in special groups of goods listed in the law. (Legislation of Ukraine)

An important nuance: the old information about a fine in the "double the value of the goods" for this norm no longer corresponds to the current version of Article 20. The current text refers precisely to the value of goods at sales prices, and not double the value. (Legislation of Ukraine)

What judicial practice shows

Judicial practice confirms a risky moment of inspections: the failure to provide documents precisely during the inspection can be considered an independent basis for a fine under Article 20 of Law No. 265, even if the entrepreneur tries to provide documents later. The Supreme Court drew attention to this in an overview of the current practice of the Cassation Administrative Court.

For business, this means a simple rule: inventory accounting must not only be kept but also be ready to show the inspector immediately at a specific place of sale. Documents that "are somewhere with the accountant" or "can be sent later" do not automatically eliminate the risk of a sanction. (Legislation of Ukraine)

Checklist for FOP

Inventory accounting in Торгсофт software

To keep inventory accounting in accordance with the Ministry of Finance Order No. 496, a special additional option "Inventory Accounting" has been developed in the Торгсофт program. It allows you to automatically generate the prescribed report, which records primary documentation (receipt and disposal), specifies details, and the total cost of goods.

To properly configure and maintain inventory accounting in Торгсофт, follow this algorithm:

1. Activation and basic settings

After purchasing the option, go to the main menu of the program Settings - Parameters - Additional options. A section "Inventory accounting form" will appear in this window. You need to activate the parameter "Use for current workplace" and save changes.

2. Launching the form and fixing initial balances

Direct work with the report is carried out in the menu Warehouse - Inventory accounting form. Work on this form should start by setting the filter "Date of start of accounting". This is the actual date from which you, as a FOP, are required to keep this accounting. After selecting the date, the program will automatically calculate the initial balances for this day. The first row in the table will be the record "Type – Initial balances". The amounts column will display the total cost of all goods that were in the warehouse on the selected date.

3. Configuring accounting centers (retail outlets)

By default, the program generates a report for the current accounting center. However, if your single business unit (physical store) is divided into several accounting centers in the program (for example, a separate "Sales Floor" and a separate "Warehouse"), you can select them all in the corresponding filter. In this case, documents from all selected centers will be displayed in a single chronological report.

4. Using filters for FOP

5. Printing the established form and FOP details

The main action on the form is the "Print" button, which opens a ready-for-tax preview of the Inventory Accounting Form. In order for the printed document to correctly display the information block about the entrepreneur (full name, tax address, TIN/EDRPOU), this data must be previously filled in correctly and carefully in the settings of the Retail Network, Enterprise, and Accounting Center. If any field remains empty, the program may substitute data from another form, which will lead to an error in the report. As a reliable alternative, the program allows you to manually configure a print form template for each accounting center. This guarantees that the report will always state the correct details of exactly that FOP who is required to provide the document to the controlling authority.

Official sources

Програма обліку товару для інтернет-магазинів, крамниць, торгових точок, складів та виробництва