Business inspections in Ukraine

Business inspections in Ukraine: what is actually checked in 2026 and how to prepare your business

In 2026, there is no single rule in Ukraine according to which business "is not checked" during martial law. The system works differently: different regimes apply to different areas. Tax audits are conducted according to the rules of the Tax Code and its martial law transitional provisions, labor inspections are partially restored on separate grounds, market surveillance over non-food products also continues, and for most other types of state supervision, military restrictions and special exceptions continue to apply. (Legislation of Ukraine)

For an entrepreneur, this means one thing: you need to prepare not for an abstract "inspection in general", but for specific scenarios. For a store, this is primarily tax, RRO/PRRO, inventory accounting, employee registration, consumer rights, product safety and labeling, and for certain types of activities, also licenses, excise requirements, advertising, prices, and personal data. (Legislation of Ukraine)

What business inspections actually exist

For most business entities, inspections can be divided into six major blocks: STS tax audits, inspections in the field of RRO/PRRO application, labor inspections by the State Labor Service, inspections in the field of market surveillance of non-food products, inspections in the field of consumer protection and distance selling, as well as inspections of licensing conditions and special rules in excisable and other regulated areas. Each block has its own grounds, procedures, deadlines, and consequences. (Legislation of Ukraine)

The general framework for most non-tax inspections is determined by Law No. 877-V. It is this law that establishes the basic rules for admission, referral, deadlines, grounds for unscheduled measures, business rights, and inspector duties. But this law does not replace special rules for tax audits, market surveillance, food control or control in the field of labor — these areas have their own specialized norms. (Legislation of Ukraine)

General rules for admission to a non-tax inspection

Before the start of a state supervision measure, the official must present an official ID and an inspection referral, as well as provide a copy of the referral to the business entity. Without these documents, the inspector has no right to conduct the inspection, and the business has the right not to admit them. This is one of the main procedural guarantees for the entrepreneur.

An unscheduled measure cannot be carried out "just because the authority decided so". The basis must strictly correspond to Article 6 of Law No. 877-V, and the business entity must be familiarized with it and receive a copy of the referral. For an unscheduled measure, the period cannot exceed 10 working days, and for small businesses — 2 working days. Extension of this period is not allowed.

The inspection of a legal entity must take place in the presence of the manager or a person authorized by them, and the inspection of an individual entrepreneur — in the presence of the entrepreneur themselves or their authorized representative. During the inspection, the seizure of original financial and economic, accounting and other documents, as well as computers and their parts, is not allowed, unless otherwise expressly provided by criminal procedural legislation. If the business has an inspection registration log, the inspector makes an entry in it before the start of the measure.

During martial law, the general rule for many types of state supervision remains restrictive: Cabinet of Ministers Resolution No. 303 suspended scheduled and unscheduled state supervision measures, but with exceptions for areas where there are significant risks to human rights, life, health, environment, state security, or Ukraine's international obligations. Therefore, in some areas, inspections are hardly applied, and in others — on the contrary, they are carried out quite actively. (Legislation of Ukraine)

Tax audits: what the STS can do

The Tax Code in its current version as of January 1, 2026, provides for three basic forms of tax control that business experiences most often: desk, documentary, and factual audits. Documentary audits are divided into scheduled and unscheduled. A scheduled documentary audit must be included in the schedule plan, and an unscheduled one is carried out only on the grounds expressly defined by Article 78 of the TCU. (Legislation of Ukraine)

A desk audit is a check of reporting without visiting the taxpayer. It is conducted based on tax return data and STS information systems. The general term for such an audit for a declaration or an clarifying calculation is 30 calendar days after the deadline for submission, and if the reporting was submitted late — after the actual submission day. Special deadlines under Article 200 of the TCU apply to declarations claiming VAT budget refunds.

A documentary audit is already an analysis of primary documents, registers, accounting, reporting, calculations, and grounds for forming tax indicators. An unscheduled documentary audit is possible only if there is a legal basis. Typical grounds include, in particular, failure to provide explanations to a written STS request in the presence of tax information about a violation, individual cases of checking a VAT budget refund, liquidation or reorganization, as well as other grounds from Article 78 of the TCU.

An unscheduled documentary audit cannot begin without handing over a copy of the order to conduct it before the audit starts. For an unscheduled off-site documentary audit, with some exceptions, the rule applies that it starts no earlier than the 30th calendar day after sending a copy of the order and written notification of the date and place of the audit. The taxpayer's presence during an off-site documentary audit is not mandatory.

A factual audit is an "on-site" check where the business actually operates: in a store, cafe, warehouse, or point of sale. It is precisely within the framework of factual audits that the STS usually checks RRO/PRRO, issuance of checks, availability of licenses, circulation of excisable goods, cash discipline, inventory accounting, and specific factual aspects of formalizing employees. The procedure for a factual audit is defined by Article 80 of the TCU, and an act based on its results is drawn up in duplicate.

During martial law, there is no complete ban on tax audits. The official position of the STS is that since August 1, 2023, desk, certain documentary, and factual audits have been resumed, and unscheduled documentary audits are conducted on the grounds defined by the Code and subject to safe conditions. In 2026, the STS also works according to the schedule plan of scheduled documentary audits published on December 24, 2025. (vin.tax.gov.ua)

The schedule plan for scheduled documentary audits for 2026 contains four sections: audits of legal entities, financial institutions, and permanent representations of non-residents, individuals, and separately audits regarding personal income tax, military tax, and unified social tax. The STS expressly indicates that the selection for the plan is carried out using a risk-oriented approach. (tax.gov.ua)

What the tax office checks most often in a store or retail network

For retail, the main risks are concentrated not around "beautiful accounting," but around simple factual things: whether a transaction was conducted through an RRO/PRRO, whether a check was issued, whether cash and actual sales correspond to the reflected transactions, whether there are documents for the goods, whether inventory accounting is maintained, whether there is a license for excisable goods, and whether the point of sale trades in goods with restricted or prohibited circulation without proper permits. (rv.tax.gov.ua)

The tax office also evaluates explanations for reporting, the presence of discrepancies between reports, timely payment of taxes, and the reality of business transactions. If a business claims a VAT budget refund, submits clarifying calculations, is liquidated, or is included in the plan according to risk criteria, attention to it increases. (tax.gov.ua)

RRO and PRRO: highest risk zone for retail

Law No. 265/95-VR remains the basic act for all settlement transactions in trade, catering, and services. The entrepreneur is obliged to conduct settlement transactions through a registered RRO or PRRO in fiscal mode and issue a settlement document in paper or electronic form to the buyer. For e-commerce, payment must also be confirmed by a proper document indicating the settlement date.

Financial sanctions are applied for making a settlement without an RRO/PRRO, for an incomplete amount, or without issuing a check. Currently, the rule is: 100% of the value of goods, works, or services sold with a violation for the first violation and 150% — for each subsequent one. This is one of the most painful sanctions for small and medium-sized businesses. (zir.tax.gov.ua)

The fiscal check must correspond to the form and contain mandatory details defined by the Ministry of Finance Order No. 13. The current version of this act takes into account the changes introduced by Ministry of Finance Order No. 601 dated 11/22/2024. Among the key details are the date and time of the transaction, the fiscal number of the document, the fiscal number of the RRO/PRRO, and a QR code that allows identifying the check through the STS system. (Legislation of Ukraine)

For retail, not only the check but also inventory accounting has become critically important. If during an inspection it turns out that a product is not accounted for or there are no documents at the point of sale confirming its accounting, a sanction in the amount of the value of such unaccounted goods at sales prices is applied to the business, but not less than 10 tax-free minimum incomes of citizens. At the same time, primary documents are an integral part of such accounting. (rv.tax.gov.ua)

A separate wartime benefit for some unified tax individual entrepreneurs without VAT in the field of RRO does not mean complete immunity. It does not apply, in particular, to the sale of excisable goods, technically complex household goods subject to warranty repair, medicines, medical devices, and jewelry. For such categories, the risk of fines remains.

Documents for goods and primary accounting

To inspect a retail business, it is not enough to "have the goods." You must have documents showing where it came from, how it was received, where it is stored, and on what basis it is sold. For the tax office, this is primarily primary documents and inventory accounting, and for market surveillance — also conformity documents, labeling, instructions, data about the manufacturer, importer, or authorized representative. (if.tax.gov.ua)

For non-preservation of documents or failure to provide originals or copies of documents during tax control, the TCU provides for a separate fine: 1020 UAH, and for a repeated similar violation within a year — 2040 UAH. This does not replace other sanctions if, due to the lack of documents, the tax office accrues additional taxes or applies a fine for inventory accounting.

Labor inspections: what the State Labor Service looks at

During martial law, labor inspections have not disappeared. According to the official clarification of the State Labor Service, inspection visits are conducted, in particular, at the request of an employee, on behalf of the Prime Minister of Ukraine, as well as in the event of an accident. The main topics of such inspections during martial law are the formalization of employment relations, the legality of terminating employment contracts, and compliance with Law No. 2136-IX on the organization of labor relations under martial law. (dsp.gov.ua)

For an employer, the key rule here is this: they check not only papers, but also the real state of labor relations. If an employee actually works but is not officially registered, if schedules, timesheets, payments, job functions and actual work do not match, if a dismissal is formalized with violations — these are direct risks of fines and disputes. (dsp.gov.ua)

A special martial law norm of Law No. 2136-IX provides for an important relief: if the employer fully and within the specified time fulfills an order to eliminate violations, fines under Article 265 of the Labor Code are not applied during martial law. But this does not mean that the order can be ignored or the situation cannot be corrected. (Legislation of Ukraine)

From October 1, 2025, the State Labor Service also received grounds to conduct unscheduled inspections on mobbing issues during martial law. For businesses, this means that internal conflicts, employee complaints, and documenting personnel decisions become even more important. (lviv.dsp.gov.ua)

Inspections of non-food products: labeling, safety, compliance

For stores selling clothes, shoes, toys, children's goods, electronics, household appliances, tools, accessories and other non-food items, state market surveillance creates a separate risk. Its task is to check whether products meet mandatory safety requirements, technical regulations, and labeling rules. (pns.dsp.gov.ua)

Market surveillance authorities conduct scheduled and unscheduled inspections of product characteristics. Scheduled inspections are carried out at distributors, and unscheduled ones — both at distributors and manufacturers. The inspection can take place both on-site and at the location of the market surveillance authority if documents are submitted there. (pns.dsp.gov.ua)

During such an inspection, the business must be ready to show documents for the product, labeling, conformity mark to technical regulations, instructions, information about the manufacturer or importer, and, if necessary, translations. It is the lack of proper labeling, instructions, or documents that often becomes the basis not for a "formal remark," but for restrictive measures against the product. (dp.dsp.gov.ua)

Law No. 2735-VI allows the market surveillance authority to demand bringing products into compliance, eliminating formal non-compliance, or temporarily prohibiting the provision of products on the market. If a product poses a risk, stricter measures are possible, up to withdrawal from circulation or recall under special procedures.

The period for checking product characteristics is limited: no more than 4 working days for a distributor and 5 working days for a manufacturer. If samples are examined or document translation is required, the time limit is suspended, but an extension of the inspection period itself is not allowed.

Businesses in the field of market surveillance have separate rights: to record the inspection on audio, photo, and video, to receive free consultative assistance, to appeal decisions, and during a scheduled inspection, even not to allow inspectors to check products that are not specified in the relevant sectoral plan.

For obstructing an inspection or denying access to check product characteristics, the law provides for significant administrative and economic sanctions. One of the expressly defined fines is 10,000 tax-free minimum incomes of citizens for creating obstacles by denying access to the inspection and failing to comply with the legal requirements of market surveillance officials.

Consumer rights, returns and delivery

For a retail business, inspections often begin not with an authority's plan, but with a buyer's complaint. That is why the rules for exchange, return, warranty, delivery, and informing the consumer are not a "service," but a part of the business's legal security. (Legislation of Ukraine)

A consumer has the right to exchange a product of proper quality within 14 days, excluding the day of purchase, if the product has not been used, its marketable condition, consumer properties, seals, labels are preserved, and a settlement document, QR code on the PRRO display, or electronic settlement document is available. The exception is goods from the list approved by the Cabinet of Ministers, which cannot be exchanged or returned on these grounds.

If a product is of improper quality, the seller or manufacturer is obliged to accept it from the consumer and satisfy the legal demand. For bulky goods and goods weighing more than 5 kilograms, delivery to the seller, manufacturer, and return to the consumer are carried out at the expense of the seller or manufacturer. If the product is in stock, a replacement request is satisfied immediately, and when a quality check is required — within 14 days or as agreed by the parties.

For refusing a consumer the realization of their rights established by Articles 8, 9, and 10 of the Law on Consumer Protection, liability is provided in a tenfold amount of the product value, but not less than five tax-free minimum incomes of citizens. This is one of the reasons why it is dangerous for a business to "simply not accept returns" when the law gives the buyer the respective right.

Distance selling, online store and delivery

For an online store, the volume of inspection risks is no less than for an offline store. Before concluding a distance contract, the seller must provide the consumer with information about themselves, location and procedure for accepting claims, main characteristics of the goods, price including delivery, payment terms, warranty, delivery conditions, and the procedure for terminating the contract.

Law No. 675-VIII explicitly establishes that a buyer in e-commerce is equated in the scope of their rights to a consumer when concluding a contract outside retail premises or at a distance. That is, online sales do not narrow the buyer's rights.

After receiving payment, the seller, another person who accepted the payment, or a payment intermediary must provide the buyer with an electronic document, receipt, goods or cash check, ticket, coupon, or other document confirming the receipt of funds, indicating the date of settlement. If payment is made without fulfilling other terms of the offer, such payment is considered improper and is subject to return.

In distance selling, it is important not only to receive payment and ship the goods but also to have clear rules for delivery, return, payment identification, order confirmation, as well as properly formalizing the collection of buyers' personal data. These issues often become a source of complaints, and subsequently — inspections. (Legislation of Ukraine)

Personal data of buyers and employees

Law No. 2297-VI applies to any processing of personal data by both automated and non-automated means. For a business, this means that the client database, phones for delivery, email addresses, loyalty questionnaires, CRM, call recordings, HR files, and copies of employee documents — all this must be processed on a legal basis.

Legal grounds for personal data processing are, in particular, the person's consent, the necessity to conclude or perform a contract, fulfillment of a duty provided by law, as well as protecting the legitimate interests of the personal data owner or a third party, if the rights of the data subject do not prevail. When collecting data, the person must be informed about the data owner, the composition and content of the collected data, their rights, the purpose of collection, and the persons to whom the data are transferred.

In e-commerce, the use of personal data is possible only provided the e-commerce subject creates proper conditions for their protection. For a store, this means a minimum: a public privacy policy, defined purpose of data collection, restricted access within the company, control over data transfer to delivery services, payment services, and contractors.

Digital goods and digital services

If a business sells not only physical goods but also digital content or digital services — subscriptions, accesses, online cabinets, electronic keys, educational materials, digital services — Law No. 3321-IX operates separately. The contractor must provide digital content or a service that meets legal requirements and does not violate the rights of third parties, including intellectual property rights.

For single or multiple provision of digital content, the contractor is responsible for a non-conformity that existed at the time of provision and was discovered within two years. For continuous digital services, liability lasts throughout the entire agreed provision period. If there is a non-conformity, the consumer may demand bringing it into compliance, a price reduction, or withdraw from the contract.

Prices, promotions, and advertising

If a business works with goods or services subject to state regulation of prices or maximum markups, inspections may concern not only sales facts but also the procedure for forming and applying a price itself. Law No. 5007-VI determines that authorized bodies carry out state control in the field of pricing, and administrative and economic sanctions under Article 20 of this Law are provided for violating the rules for applying state-regulated prices. (Legislation of Ukraine)

Advertising violations can also become a reason for claims by controlling authorities. The Law "On Advertising" in its current version requires that the advertising language be the state language, and also contains specific prohibitions and restrictions regarding certain product categories and advertising distribution channels. For electronic communications, the law explicitly prohibits certain methods of advertising influence without observing established requirements.

Licenses and permits: when an inspection results in more than just a fine

For licensed types of activities, an inspection is dangerous in that the consequence can be not only a fine but also a suspension of the license, a demand to eliminate a violation, restoration only after fulfilling orders, or complete termination of the right to work in the relevant area. The general rules for suspension, restoration, and cancellation of a license are established by Article 16 of Law No. 222-VIII. (Legislation of Ukraine)

For the sale of alcohol, tobacco products, e-cigarette liquids, raw tobacco, and other excisable categories, the special Law No. 3817-IX applies. It is this law that regulates licensing in this area and related registries. The STS officially notes that since January 1, 2025, the provisions of Chapter VII of this Law on licensing have entered into force, and in some cases, an inspection act on an established violation can become a basis for terminating a license. (Legislation of Ukraine)

For an entrepreneur, this means that in areas with licensing, it is necessary to control not only the existence of the license itself but also the actual fulfillment of the conditions of its validity: address of the place of business, cash register equipment, personnel, operating mode, assortment, documents for goods, sales method, advertising, and actual circulation of goods. (Legislation of Ukraine)

What a business must have in order before inspectors arrive

For most inspections, an entrepreneur needs to maintain in good condition not just one "paper," but a whole system of documents and processes. In retail trade, this is at least: registration and permit documents, premises documents, orders and HR documents, documents for goods and inventory accounting, properly configured RRO or PRRO, correct checks, payment confirmations, return rules, consumer documents, personal data processing policy, and for certain goods — conformity documents, instructions, labeling, and licenses. (if.tax.gov.ua)

The weakest point of most inspected businesses is not "complex schemes," but the gap between actual work and what can be confirmed by documents. If the product is there but there are no documents; if an employee works but there is no order or notification; if a check does not contain mandatory details; if a site sells a product but does not provide mandatory information to the buyer; if a product is subject to a technical regulation but lacks proper labeling — this is already enough for problems. (rv.tax.gov.ua)

Checklist for preparing a business for an inspection in 2026

1. Before the inspection

2. During the inspection

3. After the inspection

Conclusion

In 2026, the main risk for business is not the inspection itself, but being unprepared for it. For a store, online store, network of sales points, or service business, a secure model looks like this: transparent inventory accounting, properly formalized settlements, confirmed documents for goods, registered personnel, order in returns and consumer information, correct processing of personal data, and for special areas — flawless fulfillment of licensing and technical requirements. This is exactly the system that best protects both the money and the reputation of the business. (Legislation of Ukraine)

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