Gift certificates in the store: sales, ECR/PECR, taxes, returns and accounting

Gift certificates: sales, fiscalization, taxes, returns and accounting

Gift certificates can be legally sold in a store, through a website or social media, but the business must define their terms in advance, set up fiscalization, and separate the receipt of prepayment from the subsequent transfer of goods. Funds received from a buyer for a certificate by a Sole Proprietorship — a single tax payer — are included in income on the day they are received and are taken into account when determining the annual income limit. When a certificate is redeemed, the buyer must be issued a fiscal receipt containing the full list of goods actually transferred, with the certificate specified as a means of cashless payment.

The greatest tax risk arises for Sole Proprietorships under the single tax system in groups one through three. The State Tax Service directly regards the receipt of goods in exchange for a previously purchased gift certificate as a non-monetary form of settlement. This may result in the application of an increased single tax rate to the relevant income and a mandatory transition to the general taxation system. The name of the transaction in the accounting software — «certificate», «deferred discount» or «product» — does not in itself change its tax substance. Before launching paid fixed-value certificates, a Sole Proprietorship under the simplified taxation system should obtain an individual tax consultation regarding the specific model of their sale and use.

What a gift certificate means from a legal perspective

Ukrainian legislation does not contain a separate universal definition of a store gift certificate. In a standard retail model, it confirms that the seller has received funds from the buyer and has undertaken to transfer goods or provide services to the certificate holder in the future under specified terms.

A certificate is not an independent means of payment equivalent to the hryvnia. Its legal significance is determined by:

• the terms of the seller’s contract or public offer;

• the certificate value and validity period;

• the list of stores, goods or services for which it is valid;

• the rules for one-time or multiple use;

• the procedure for accounting for the unused balance;

• the terms for additional payment, refunds and restoration;

• the actual flow of funds and goods.

The seller’s obligations must be properly fulfilled in accordance with the terms of the contract and the law. If a store serves an unlimited number of consumers, the certificate rules effectively become part of a public contract and may not contain unfair terms that create a significant imbalance to the detriment of the buyer.

Is a gift certificate a financial or payment service?

A standard certificate accepted only by the issuing store or its own retail network should not automatically be treated as electronic money. Under the Law «On Payment Services», electronic money must be accepted as a means of payment by persons other than its issuer. In a closed-loop model where the certificate is redeemed exclusively with its seller, this defining feature is usually absent. This means that a separate license for financial payment services is generally not required solely because a business issues its own store certificates.

Additional analysis under payment services legislation is required if the certificate:

• is accepted by independent sellers that are not units of the same issuer;

• can be transferred between electronic wallets;

• can be exchanged for cash;

• is used for transfers between individuals;

• functions as a multi-purpose payment instrument.

Licensing requirements for alcohol, tobacco products, medicines and other regulated goods continue to apply when they are sold using a certificate. A certificate does not cancel age restrictions, minimum prices, labeling rules, accounting requirements or product code programming requirements.

What certificate rules should be approved

The terms of use should be formalized in a separate policy or public offer. The buyer must be able to review them before payment — in the store, on the website or via a link provided together with an electronic certificate.

The rules should specify:

1. The full name of the legal entity or details of the Sole Proprietorship, tax number, address and contact details.

2. The certificate value and currency.

3. The start and expiry dates.

4. The stores, websites, goods and services for which it is valid.

5. The activation point: immediately after payment or after a separate transaction.

6. Whether partial use is permitted.

7. What happens to the unused balance.

8. Whether several certificates can be combined in one receipt.

9. The procedure for additional payment in cash or by card.

10. Compatibility with bonuses, discounts and promotions.

11. The rules for returning the certificate itself and goods purchased with it.

12. The procedure for restoring a lost electronic or personalized certificate.

13. The consequences of expiry and the procedure for extending the validity period.

14. Restrictions on exchanging the certificate for cash.

15. The procedure for handling requests and complaints.

The consumer has the right to receive necessary, accurate and timely information about the terms of use before making a purchase. Concealing the validity period, restrictions, balance rules or the list of participating stores may be regarded as a violation of the consumer’s right to information. Incomplete or inaccurate statements about the certificate value, discounts and material terms of the contract may also be classified as misleading information.

The law does not establish a single minimum validity period for all store gift certificates. The seller determines the validity period, but it must be clearly communicated to the buyer and must not create unfair consequences. To reduce disputes, it is advisable to provide a sufficient validity period, the possibility of extension or the use of the remaining balance, especially if the store continues to operate and is able to fulfill its obligation.

A free discount coupon and a paid certificate are different models

A free promo code or coupon distributed by a store as part of a promotional campaign does not confirm receipt of a prepayment. It only reduces the price of goods according to the promotion rules.

A paid certificate with a fixed value confirms that the store has already received money and has undertaken to provide goods in the future. Renaming such an instrument in the software as a «deferred discount» does not guarantee that the State Tax Service will recognize it as an ordinary discount. The tax authority assesses the actual substance of the transaction: whether the buyer paid money, whether they acquired the right to claim goods, and how that right is redeemed.

Gift certificates for Sole Proprietorships under the single tax system

When income arises

For a Sole Proprietorship — a single tax payer — income consists of funds received in cash or by cashless payment. The date of income is the day the funds are actually received. Therefore, payment for a certificate is included in the Sole Proprietorship’s income on the day of:

• receipt of cash at the checkout;

• card payment;

• receipt of funds through online acquiring;

• crediting of a bank transfer to the business account.

It does not matter whether the certificate recipient uses it or not. The amount received is already taken into account when determining annual income and the applicable income limit for the relevant group.

In 2026, the income limits are calculated based on the minimum wage of UAH 8,647:

Why certificate redemption creates a risk of losing single tax status

Taxpayers in groups one through three must settle payments for shipped goods, completed work or provided services exclusively in monetary form. The State Tax Service considers that when goods are transferred in exchange for a gift certificate, the seller does not receive money but instead settles a previously issued claim right. Therefore, the transaction is regarded as a non-monetary settlement.

The consequences may include:

• application of a 15% single tax rate to the relevant income received using another form of settlement;

• mandatory withdrawal from the simplified taxation system from the date specified by the Tax Code;

• cancellation of single tax payer registration following an audit;

• additional assessment of taxes under the general taxation system for the period during which the entrepreneur was no longer entitled to use the simplified taxation system;

• fines and penalties for late payment of the relevant taxes.

This does not mean that the tax authority may arbitrarily cancel the status retroactively for any previous date. The Tax Code links the transition and cancellation to the specific reporting period in which a prohibited form of settlement was used.

Practical solution for a Sole Proprietorship

A Sole Proprietorship under the single tax system may sell certificates, but the official position of the State Tax Service makes their subsequent redemption tax-risky. The more protected options are:

• to operate the certificate program through a legal entity or a Sole Proprietorship under the general taxation system;

• to use free discount coupons instead of paid fixed-value certificates;

• to obtain an individual tax consultation with a detailed description of the sales, fiscalization, redemption and return process;

• not to rely solely on the name of the payment method or the mode selected in the software.

An individual tax consultation protects only the taxpayer to whom it was issued, provided that the actual business model corresponds to the model described in the consultation request.

Accounting for legal entities

For a company, funds received in advance for a certificate are not recognized as accounting income at the time of receipt. National Accounting Standard 15 expressly excludes prepayments and advances from income. Until the goods are transferred, the company records a liability to the certificate holder.

Income is recognized in accordance with accounting rules after the conditions for its recognition have been met, including when the goods are transferred. Unused certificates should not automatically be recognized as profit merely because the internal validity period of the card has expired. The terms of the contract, the possibility of a customer claim, the accounting policy and the criteria for derecognition of the liability must be taken into account.

VAT on the sale and use of a certificate

For a VAT payer, receipt of payment for a certificate is the first taxable event. VAT liabilities arise on the date of payment and a tax invoice is issued.

When the certificate is redeemed:

• the transfer of goods is the second event and does not in itself create additional VAT on the amount already paid;

• the item description in the tax invoice must be brought into line with the goods actually transferred by means of an adjustment calculation;

• if the buyer pays an additional amount, the additional payment has tax consequences under the general rules;

• if the goods are subject to different VAT rates or some of them are VAT-exempt, the adjustment must correctly allocate the actual items and applicable rates.

The procedure for completing the tax invoice and adjustment calculation should be agreed with an accountant, taking into account the product range, VAT rates and whether the specific goods to be purchased are known on the date the certificate is sold.

Sale of a certificate via ECR or PECR

Payment in cash, by card or through acquiring

If the buyer pays for the certificate:

• in cash;

• by bank card through a POS terminal;

• by card on the website;

• through LiqPay, Portmone, WayForPay, another online acquiring service or a payment link,

the transaction must be processed through an ECR/PECR for the amount actually received, and the buyer must be provided with a paper or electronic fiscal receipt.

The State Tax Service recommends indicating «advance payment for...» in the first receipt when receiving a prepayment, together with the product name, SKU or another identifier. For a certificate program, the item description must clearly indicate the substance of the transaction, for example: «Gift certificate with a value of UAH 1,000» or «Advance payment for goods — gift certificate No....».

Direct transfer to IBAN

If the buyer is provided with the full details of the business current account in IBAN format and independently transfers funds from one account to another without card acquiring, receiving such an advance payment without simultaneous transfer of goods does not require an ECR/PECR. The advance amount must subsequently be reflected in the fiscal receipt generated when the goods are transferred or during the next settlement transaction.

A transfer to a personal card number, key card or payment link should not be treated as a direct transfer using IBAN details. For the ECR exemption to apply, the transaction must specifically be a bank transfer from one account to another without the seller using card acquiring.

Payment for goods with a gift certificate via ECR/PECR

When the buyer selects the goods, the seller must generate a fiscal receipt containing the full list of goods actually transferred:

• name;

• quantity;

• price;

• VAT rate;

• amount;

• UKT ZED code and other mandatory details — for goods for which they are required;

• payment form and payment method.

The State Tax Service recommends showing the amount covered by the certificate as the payment form «CASHLESS», while specifying «gift certificate» in the payment method field. If the buyer pays an additional amount, the receipt must indicate all payment forms used and the amount paid by each method.

For example, a buyer purchased goods worth UAH 1,300 and used a certificate with a value of UAH 1,000. The receipt must include all goods totaling UAH 1,300, while the payments must show:

• UAH 1,000 — «CASHLESS», payment method «gift certificate»;

• UAH 300 — cash or card, depending on how the additional payment was actually made.

The free «PECR STS» software solution does not support a separate function for settlements using gift certificates. Such a process may require a commercial PECR that allows the relevant payment form and payment method to be transmitted.

Does using two receipts create double income?

A fiscal receipt does not itself determine taxable income. The first receipt confirms receipt of the advance payment, while the second confirms the transfer of specific goods and application of the advance payment received earlier.

Two correctly generated receipts do not mean that the entrepreneur received the money twice. The final receipt must show:

• the full list of goods;

• the full price;

• the previously paid advance or certificate payment;

• the actual additional payment amount.

The State Tax Service expressly provides that the final receipt may be generated even without a new payment if the entire cost of the goods was previously covered by an advance payment.

Double recognition may occur if the software is incorrectly configured during certificate redemption as though the store were receiving new funds again. Therefore, cash register, management and accounting records must link the initial sale of the certificate to its redemption.

Electronic certificates, website sales and delivery

When selling an electronic certificate through a website or another electronic channel, the seller must provide the buyer with direct and permanent access to information about the seller, the price, contract terms, payment procedure and, where applicable, information about the license for the main business activity. The electronic offer must contain the material terms of the contract.

After payment, the buyer must be provided with:

• an electronic certificate or unique code;

• the terms of use or a permanent link to them;

• order confirmation;

• an electronic fiscal receipt if the transaction is subject to fiscalization;

• contact information for inquiries and access restoration.

If the certificate is sent to a recipient using their name, email address or telephone number, the store processes personal data. It is necessary to define a lawful purpose and legal basis for processing, collect only the information that is necessary, inform the person about the data controller and avoid retaining the information longer than required for the specified purpose.

Validity period and unused balance

A store may provide for one-time use of a certificate, multiple deductions or a requirement to make a purchase for at least the certificate value. However, these rules must be communicated to the buyer before payment.

The wording «the remaining balance expires» creates an increased risk of disputes if:

• the rule was printed inconspicuously;

• the buyer did not receive the terms before payment;

• the validity period was excessively short;

• the store refuses to fulfill its obligation despite being able to do so;

• the seller reserved the right to change the terms at its sole discretion.

To protect its reputation and reduce complaints, it is advisable to allow the balance to be retained, reissue the certificate for the unused amount or establish a validity extension procedure. If a one-time-use model without change is used, this must be clearly highlighted on the certificate itself and in the offer. At the same time, contractual terms may not restrict mandatory consumer rights or release the seller from liability for its own failure to perform.

Returning the gift certificate itself

The law does not establish a separate universal procedure for returning all store certificates. The procedure depends on:

• the content of the contract;

• the method of purchase;

• whether the certificate has been activated or used;

• the reasons for the return;

• the seller’s compliance with its information obligations;

• whether the store has committed a breach.

The rules may state that the certificate cannot be exchanged for cash at the holder’s request. However, such a condition must not deprive the buyer of the right to demand a refund where the store itself cannot or refuses to fulfill its obligation, ceases operations, provides inaccurate information or materially breaches the contract.

For distance sales, consumer rights under a distance contract must be considered separately. The mere fact that a code is sent by email does not automatically turn the certificate into digital content: it may only certify the right to receive ordinary goods or services in the future.

Returning goods purchased with a certificate

Payment by certificate does not cancel warranty or other consumer rights relating to the purchased goods.

For defective goods, the requirements of Article 8 of the Law «On Consumer Protection» apply: price reduction, remedy of defects, reimbursement of expenses and, in the event of a material defect, replacement or termination of the contract and refund of the amount paid.

Non-food goods of proper quality may be exchanged within 14 days, excluding the day of purchase, provided that their commercial appearance and consumer properties are preserved and other statutory conditions are met. This rule does not apply to goods included in the established list of products that are not subject to exchange or return. If an exchange is impossible, the consumer may terminate the contract and receive a refund equal to the value of the returned goods.

When processing a return, it is necessary to distinguish between:

• certificate as payment — the original receipt shows the amount as a separate payment method;

• a genuine discount — the receipt already shows a reduced product price and the buyer does not transfer to the store a previously purchased claim right.

Settlement with the buyer is carried out based on the value of the goods in accordance with Articles 8 and 9. The return transaction must be processed through an ECR/PECR and linked to the original fiscal document. Automatically paying the certificate holder the entire certificate value in cash may create an unjustified opportunity to convert it into cash. Automatically refusing to refund any amount solely because the goods were paid for with a certificate may violate mandatory consumer rights.

The return procedure should be agreed in advance with the accounting policy and the capabilities of the ECR/PECR: restoring the certificate, issuing a new certificate, refunding the original payer or another lawful method must not impair consumer rights guaranteed by law.

Documents and internal control

For each certificate program, it is advisable to have:

• an approved policy or public offer;

• an order introducing the certificates and appointing responsible persons;

• a register of issued numbers or barcodes;

• data on value, sale date, activation, redemption and balance;

• a fiscal receipt or bank statement confirming payment;

• a final receipt containing the list of transferred goods;

• return and adjustment documents;

• tax invoices and adjustment calculations for VAT payers;

• inventory reports for unused certificates;

• instructions for cashiers;

• segregation of access rights for issuing, cancelling, reissuing and redeeming certificates.

Cashiers must understand the difference between selling a certificate, activating it, redeeming it, accepting an additional payment and processing a return. No special professional license or employee qualification is required for operations with a store’s own certificates, but access to generating and reissuing codes should be restricted to prevent unauthorized issuance and repeated use.

There are no separate general government requirements for premises, labeling or storage specifically applicable to the paper or plastic certificate itself. However, businesses should use secure barcodes, unique numbers, activation statuses and user activity logs. Requirements for the storage, labeling and sale of the actual goods provided in exchange for a certificate continue to apply in full.

Inspections and liability for ECR/PECR violations

Business entities must process settlement transactions through an ECR/PECR for the full amount and issue the buyer a settlement document in the prescribed form.

For failure to process a transaction through an ECR/PECR, processing it for an incomplete amount or failing to issue a proper receipt, Law No. 265 provides for financial penalties:

• 100% of the amount of the transaction conducted in violation — for the first violation;

• 150% — for each subsequent violation.

An on-site inspection of settlement transactions may be conducted without prior notice where grounds provided by the Tax Code exist. Before beginning the inspection, the supervisory authorities may conduct a test settlement transaction, including purchasing a certificate or goods using one. At the same time, the inspectors must have an inspection order, authorization and official identification documents, and a copy of the order must be provided before the inspection begins.

Gift certificates in Torgsoft: issuance, sale, fiscalization, redemption and analytics

In Torgsoft, gift certificates become available after activating the additional «Gift certificates» feature. The software allows you to issue certificates with unique barcodes, define their value and validity period, sell them from the «Sales» form, accept them as payment for goods, and check whether a specific certificate has been sold, used or expired.

If the purchase amount exceeds the certificate value, Torgsoft calculates the additional payment. If the amount is lower, the standard software logic processes the sale without giving change, so this condition must comply with the store’s published rules.

The software supports three internal models:

For the «As a product» mode, a goods receipt document is created after issuance, certificates are accounted for by accounting center, and once used they cannot be reissued. This mode also has software restrictions regarding sales on credit and sales with invoice issuance.

To fiscalize certificates in the «As a product» mode, the «Fiscal» attribute must be enabled for the «Gift certificate» system product type. The «Paid with gift certificates» variable can be added to the non-fiscal and fiscal PECR receipt template. In the goods report and analysis report, you can monitor the amounts of used and unused certificates, additional payments, goods paid for with certificates, and transaction history.

The mode selected in Torgsoft determines the internal logic of sales, inventory accounting, discounts and reports, but does not replace the legal and tax assessment of the transaction. For a Sole Proprietorship under the single tax system, the «As a deferred discount» mode does not automatically provide protection if the buyer first pays the certificate’s fixed value and later presents the certificate instead of money when purchasing goods.

Procedure for launching a certificate program

Before starting sales, the entrepreneur should:

1. Determine who will be the issuer: a Sole Proprietorship, legal entity or separate company within the retail network.

2. Check whether the model is compatible with the applicable taxation system.

3. For a Sole Proprietorship under the single tax system, obtain an individual tax consultation or choose another loyalty model.

4. Approve the certificate rules and publish them before sales begin.

5. Define the procedure for accounting for prepayments, VAT, redemption and unused amounts.

6. Configure the ECR/PECR for the first receipt and the final receipt containing the full list of goods.

7. Check whether the payment method «gift certificate» can be specified.

8. Configure access rights, unique codes and controls against repeated redemption.

9. Develop a lawful procedure for returning the certificate and goods.

10. Train cashiers and perform test transactions for sale, redemption, additional payment and return.

11. Reconcile management reports with fiscal receipts, bank receipts and accounting records.

Official sources

1. Tax Code of Ukraine dated 02.12.2010 No. 2755-VI — paragraphs 291.4, 291.6, 292.1, 292.6, 293.4, 298.2.3, 299.10–299.11; Articles 187, 192, 201:
   https://zakon.rada.gov.ua/laws/show/2755-17

2. Law of Ukraine «On the State Budget of Ukraine for 2026» dated 03.12.2025 No. 4695-IX — Article 8:
   https://zakon.rada.gov.ua/laws/show/4695-20

3. Law of Ukraine «On the Use of Registrars of Settlement Transactions in the Sphere of Trade, Public 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

4. Order of the Ministry of Finance of Ukraine dated 21.01.2016 No. 13 «On Approval of the Regulation on the Form and Content of Settlement Documents/Electronic Settlement Documents»:
   https://zakon.rada.gov.ua/laws/show/z0220-16

5. Law of Ukraine «On Consumer Protection» dated 12.05.1991 No. 1023-XII — Articles 8, 9, 15, 17, 18:
   https://zakon.rada.gov.ua/laws/show/1023-12

6. Civil Code of Ukraine dated 16.01.2003 No. 435-IV — Articles 509, 526, 530, 626–638:
   https://zakon.rada.gov.ua/laws/show/435-15

7. Law of Ukraine «On Electronic Commerce» dated 03.09.2015 No. 675-VIII — Articles 7, 8, 11–13:
   https://zakon.rada.gov.ua/laws/show/675-19

8. Law of Ukraine «On Payment Services» dated 30.06.2021 No. 1591-IX — Articles 1, 5, 8, 57–60:
   https://zakon.rada.gov.ua/laws/show/1591-20

9. Law of Ukraine «On Personal Data Protection» dated 01.06.2010 No. 2297-VI — Articles 6, 8, 11, 12:
   https://zakon.rada.gov.ua/laws/show/2297-17

10. National Accounting Regulation (Standard) 15 «Revenue», approved by Order of the Ministry of Finance of Ukraine dated 29.11.1999 No. 290 — paragraph 6:
    https://zakon.rada.gov.ua/laws/show/z0860-99

11. Law of Ukraine «On Protection Against Unfair Competition» dated 07.06.1996 No. 236/96-VR — Article 15-1:
    https://zakon.rada.gov.ua/laws/show/236/96-%D0%B2%D1%80

12. Clarification of the State Tax Service regarding gift certificates for Sole Proprietorships under the single tax system:
    https://tax.gov.ua/

13. Clarification of the State Tax Service regarding the use of ECR/PECR when paying with gift certificates:
    https://kyivobl.tax.gov.ua/media-ark/news-ark/919537.html

14. State Tax Service knowledge base regarding fiscalization of advance payments and final settlements:
    https://zir.tax.gov.ua/main/bz/view/?id=41513&src=ques

15. Clarification of the State Tax Service regarding VAT on the sale and redemption of a gift certificate:
    https://zp.tax.gov.ua/media-ark/news-ark/744923.html