Certificates of completed work: Law No. 14023 and document flow according to new rules

Certificate of completed works in 2026: is it still mandatory, when it will be possible to work without it, and what businesses should do right now

From April 1, 2026, it will be easier for entrepreneurs to close deals: an act for services, works and leases can be drawn up in the accounting department without the client's signature. This is especially convenient for retail (rent, delivery, service), because the company no longer risks "hanging" due to papers not returned by the counterparty. For the new rule to work, it is enough to prescribe such a possibility in advance in a written contract and indicate the date or period of service provision in the act. Under such conditions, the main thing is to reflect this operation in the accounting in a timely manner.

However, this simplification does not always work and applies only to commercial transactions. Signatures of both parties remain mandatory if the transaction is related to public funds, lease of state or municipal property, construction contract, design and survey work, as well as charity or humanitarian aid. Since this is not a complete cancellation of acts, but only a convenient option for individual cases, businesses should review contract templates now so that the company's lawyers and accounting department can prepare in advance and act in a coordinated manner.

The main thing an entrepreneur needs to understand is this: Ukrainian law even now requires not “specifically an acceptance certificate,” but a primary document confirming the business transaction. This follows from the Law of Ukraine «On Accounting and Financial Reporting in Ukraine»: a primary document is a document containing information about a business transaction, and accounting records are based specifically on primary documents.

That is, if you have provided a service, performed work, or leased out property, you must have a document that records it. Most often, this has been and remains a certificate of completed works / certificate of services rendered, because it is convenient and familiar for accountants, tax authorities, banks, and courts. However, the title of the document itself is not magical. What matters more is that the document clearly shows: who did what, when, to what extent, and on what basis.

What a certificate of completed works is and why businesses needed it

A certificate of completed works or services rendered is a document by which the parties confirm that the work or service has actually been completed and accepted. For businesses, it performed several roles at once. 

First, an accounting role: it served as the basis for recognizing income, expenses, and closing mutual settlements. 

Second, a tax role: especially where it was necessary to confirm the date and the actual nature of the transaction. 

Third, a civil law role: in a dispute, it showed that the customer had accepted the result and had not raised any objections. This is also consistent with the logic of the Civil Code: under a contract for work, the customer must accept and pay for the completed work, and if there are defects — state them.

For services, the logic is the same: the provider delivers the service, and the customer pays for it. For lease agreements — the property is transferred for use for a fee, the amount of which is determined by the contract. That is why for years the acceptance certificate was a universal document understood by everyone.

Current law as of March 2026: what is mandatory now

Today, Article 9 of the Law «On Accounting and Financial Reporting in Ukraine» is in force. It states that primary documents may be prepared in paper or electronic form and must contain mandatory details: the document title, date of preparation, company name, content and scope of the transaction, positions and surnames of the responsible persons, as well as a personal signature or other data allowing identification of the person who participated in the transaction. This is directly confirmed both by the Law and by the letter of the Ministry of Finance dated 24.03.2023.

Until the new law enters into force, a bilateral document containing the details of both parties remains the safer model, especially for B2B, VAT, bank financial monitoring, audit, and disputes.

At the same time, even now the law does not state that only a document titled “certificate” has legal force. Moreover, the Ministry of Finance has officially clarified that an invoice may be used for accounting purposes if it contains the mandatory details of a primary document.

Another important point: the law directly protects businesses against minor formal mistakes. Non-material defects in documents are not grounds for refusing to recognize a business transaction if the document still makes it possible to identify the parties, the date, the content, and the scope of the transaction. In other words, a wording mistake or a technical inaccuracy does not yet make the service “non-existent,” but the substance of the document must be clear.

What exactly Draft Law No. 14023 changes

Draft Law No. 14023 does not “abolish certificates” and does not allow businesses to operate “without documents at all.” It proposes something else: in certain cases, the absence of the position, surname, and signature of the customer / tenant in a primary document will not be considered a violation if certain conditions are met. This is directly described in the official news item of the Verkhovna Rada dated 24.02.2026.

According to the official description by the Verkhovna Rada, there are two conditions:

1. such a documentation procedure must be explicitly provided for by a contract concluded in writing;

2. business transactions must be recorded in the accounting records in the period in which they are carried out.

A very important clarification: the open official description of the adopted law does not contain a condition that the service must be paid in full exclusively by bank transfer. Therefore, this statement cannot be presented as a confirmed final rule as of 09.03.2026. It is possible that such an idea appeared in public discussions or earlier versions, but it is not mentioned in the official description of the Verkhovna Rada after adoption.

Which contracts the change does not apply to

Even after the law enters into force, it will not give everyone a universal right to abandon traditional acceptance certificates. According to the official news item of the Verkhovna Rada, the simplification does not apply to:

• transactions paid for from public funds;

• lease agreements for state-owned or municipal property;

• construction contracts and design and survey work contracts;

• donation agreements, charitable aid, or humanitarian aid agreements.

Public sector entities, state property, construction, and some special areas will remain much more conservative.

Does this mean that the certificate is no longer needed

No. The correct answer for businesses is this: the certificate does not disappear, but becomes one of the options. After the law enters into force, a business will either be able to remain with the classic “invoice + certificate” model, or switch to another model where the fact of service provision / work performance / lease is confirmed by another primary document without the signature of the second party — but only where this is clearly allowed by the contract.

For a cautious entrepreneur, this means the following. If you have:

• a small number of B2B clients;

• conservative counterparties;

• budget-funded or “audit-sensitive” customers;

• VAT and large amounts;

• a risk of disputes about quality, scope, or deadlines,

then the traditional certificate will remain the most convenient tool for a long time. This is not because “nothing works” without it, but because it is easier to prove your case with it.

At the same time, the greatest benefit from the new model may be obtained by IT, consulting, marketing, subscriptions, service businesses, online services, rental, repairs, and support provided on a subscription fee basis — in other words, in areas where the certificate was often a technical “piece of paper” rather than a real point of acceptance of the work. This is already an analytical conclusion from the structure of the law, not a separate direct rule.

Which documents can work instead of the traditional certificate

Under current law and practice, a business can build its evidence base not only on the traditional certificate. These may include:

• an invoice / billing invoice, if it contains the mandatory details of a primary document;

• an electronic certificate with a qualified electronic signature;

• a service report;

• a document based on the contractual model under which “the service is considered accepted if no reasoned objections are received within the specified period”;

• a package of evidence: correspondence, technical reports, requests, tickets, links to delivered files, access logs, payment statements.

Electronic documents also have full legal force. The Law «On Electronic Documents and Electronic Document Management» directly states that the legal validity of an electronic document cannot be denied solely because of its electronic form, and its admissibility as evidence cannot be denied solely because it is electronic. The original of an electronic document is an electronic copy containing mandatory details, in particular the electronic signature of the author or a signature equivalent to a handwritten one.

The biggest tax risk: VAT and the “first event”

For VAT payers, changing the document flow model creates the greatest practical risk specifically because of the date on which tax liabilities arise. Clause 187.1 of the Tax Code establishes the “first event” rule: VAT liabilities arise on the earlier of two dates — either the date the funds are received from the buyer, or the date of the document certifying the fact of the supply of goods/services.

The traditional certificate often served as a convenient “beacon” marking the date when the service was completed. If you switch to another model, accounting must determine even more carefully which document is now considered the document confirming the fact of supply, and exactly when it is prepared. Otherwise, mistakes may occur with the reporting period, the tax invoice, or the counterparty’s tax credit.

What must обязательно be specified in the contract

If after the law enters into force you want to work without the traditional bilateral certificate, the main risk will shift from the “paper” to the contract. The contract itself will become the company’s main protection. This is especially important for Torgsoft and any other business with a large client document flow, reputational risks, and the risk of disputes about service quality.

The contract or public offer should explicitly establish:

• which exact document confirms the fact of service provision / work performance / lease;

• how this document is sent to the client;

• when the document is considered received;

• what period the client has for reasoned objections;

• what happens if no objections are received;

• through which channels documents and claims are sent;

• which additional materials confirm the reality of the service: reports, correspondence, transferred files, work logs, technical tickets, etc.

A note on the invoice alone will not save the situation if the contract is silent or drafted vaguely.

A brief practical example

There is a useful reference point from court practice. In its publication dated 04.09.2023, the Supreme Court in case No. 910/5352/21 emphasized that legal consequences are created by the business transaction itself — that is, the actual performance of work or provision of services — rather than merely by the existence of primary documents. A certificate alone without a real service does not help, but the opposite is also true — sometimes the substance of the transaction is more important than the form.

This is a good signal for businesses: after the reform, the key factor will not be the word “certificate,” but the evidential proof of the actual provision of the service.

What businesses should do right now, before the law enters into force

Until the law is signed and published, the safe strategy is as follows:

1. Do not massively abandon certificates right now. As of 09.03.2026, this would be premature.

2. Audit your contracts. Check where you already have written form, electronic document management, an offer mechanism, objection periods, and a service acceptance procedure.

3. Review your accounting policy and document management rules. You need to determine which document will be the primary one in each scenario: a certificate, an invoice, an electronic certificate, or a service report.

4. For VAT, establish a clear cut-off. The accountant must know exactly which date is considered the date of service supply and which document confirms it.

5. For intangible services, collect additional evidence. Reports, tasks, correspondence, technical tickets, links to transferred files, electronic messages — all of this helps prove the reality of the transaction.

Practical steps for users of the Torgsoft accounting software during the transition period and after the law enters into force

1. Configure two operating scenarios in Torgsoft: “conservative” and “new”

Torgsoft officially has a mode called «Document — Trade with Invoice Issuance», where invoices can be created and printed. There are also print template settings. For invoices, the official help page directly shows the printing path: «Document — Trade with Invoice Issuance — Invoice — Print Invoice — Print Invoice». There is also a separate section called «Print Template Settings».

In practice, this means:

• for conservative B2B clients, budget-funded customers, construction, disputed or large contracts — keep the classic scenario with a certificate;

• for mass services, service support, subscription fees, public offers, and small orders — prepare a scenario in which the primary document will be a properly prepared invoice or another document provided for by the contract.

2. Prepare a separate invoice template, but do not replace the contract with it

In Torgsoft, you can print invoices and configure print templates. The system supports variables for documents in the “Trade with Invoice Issuance” mode, and FastReport is used to edit templates in the system.

What we recommend doing in practice:

• create a separate invoice template for clients with whom you plan to switch to the simplified model;

• add to the template not “legal magic,” but a reference to the contractual acceptance mechanism.

A safer wording for the template would be approximately as follows:

«This document is prepared pursuant to Agreement No. __ / Public Offer. The procedure for confirming the fact of service provision, the period, and the method for submitting reasoned objections are determined by the agreement. If no objections are received within the period established by the agreement, the services are considered accepted in the scope specified in this document».

In other words, the invoice template must refer back to the contract rather than invent new rules by itself.

3. Use payment control in Torgsoft, but not as the “only condition without a certificate”

Torgsoft has an additional function called «Bank Statements by Invoices», which, according to the official help materials, works with Privat24, Monobank, and Ukrsibbank. It allows you to import bank statements and link them to financial transactions / invoices in the system. 

In practice, during the transition period this is useful because the option helps to:

• see the actual payment date;

• control outstanding debts;

• correctly determine the first event for VAT;

• quickly prepare a reconciliation statement with the client.

For entrepreneurs, this is especially beneficial as a protective mechanism: less manual checking, fewer human errors, and an easier way to confirm payment with the bank, the accountant, and the client.

4. Public offer  and QR code directly in the invoice template

Legally, the model “public offer + acceptance + payment” is entirely workable. The Law «On Electronic Commerce» allows an electronic contract to be concluded by acceptance (for example, by payment of the issued invoice) and allows the contract terms to be included through a reference to another electronic document, provided that the client had the opportunity to review it.

From the technical side, Torgsoft implements this without any problems. Since the software uses a flexible print template editor (FastReport), you can easily add a QR code image with a link to your public offer to any document.

How to do this in practice:

• Generate a QR code containing a link to the page with the terms of your agreement (offer) on the website.

• Open the print template settings for the invoice or sales receipt in Torgsoft.

• Insert the QR code image in a convenient place on the form.

• Add a short explanatory note next to it. For example: «Payment of this invoice in full confirms the fact of service provision and acceptance of the terms of the Public Offer. You can review the text of the offer by scanning the QR code».

Such a solution automates the receipt of the client’s consent, legally protects the entrepreneur, and completely eliminates the need to collect physical signatures on paper certificates.

5. It is better to keep classic certificates in Torgsoft for “risky” counterparties

In the «Repair and Warranty Service» module, you can print a certificate of completed works, and the print template can be customized if needed. Also, after payment for repair, an invoice is automatically created in the «Trade with Invoice Issuance» mode. 

A practical recommendation for the transition period:

• for budget-funded customers, large B2B, disputed clients, construction, and the public sector — keep mandatory certificate printing;

• for small service operations and mass services — test the simplified scenario on a separate group of contracts after the law enters into force.

6. It is better to launch electronic document management right now

Even before the law enters into force, a business can eliminate paperwork through electronic document management. The law on electronic documents directly protects electronic documents as evidence, and the original of an electronic document has legal force provided it contains mandatory details and a signature.

In Torgsoft, documents can be opened for viewing with the ability to save them in various formats or send them to print. Therefore, the practical model is as follows:

• create an invoice / certificate in Torgsoft;

• open it for viewing;

• save it in an available format;

• send it via Vchasno, M.E.Doc, or another electronic document management service;

• sign it with a qualified electronic signature. 

7. For VAT payers in Torgsoft, the main thing is date discipline

Because of the first event rule, the accountant needs to control very clearly:

• the date the document is issued;

• the payment date;

• the date the service is actually provided;

• the date of the document confirming this fact.

In Torgsoft practice, this means:

• not mixing up the “print date” and the “business transaction date”;

• regularly reconciling invoices with bank statements;

• establishing an internal rule as to which specific document serves as the trigger for accounting to recognize income and register the tax invoice. 

Certificates of completed works at Torgsoft

Under Torgsoft standard licensing model, paper acceptance certificates are not signed, as this is expressly provided for by our public offer agreement. The contract is concluded by acceptance of the offer through payment, and the proper provision of the license is confirmed by the transfer of the license key, access, or activation. This approach complies with the rules on offer acceptance and electronic contracts, and the legal validity of an electronic document cannot be denied solely because of its electronic form.

Summary

As of 09.03.2026, the certificate of completed works has not been abolished in Ukraine. The new Law No. 14023 has been adopted, but it is not yet in force. After it enters into force, it will not eliminate certificates, but will give businesses the right to choose: in certain cases, to work without the customer’s signature on the primary document, if this is expressly provided for by a written contract and properly reflected in the accounting records.

The correct conclusion for an entrepreneur is not: “certificates are no longer needed.” The correct conclusion is different: “now it is necessary to work more carefully with the contract, electronic document management, and proof of the actual provision of the service.” And this is exactly the model I would recommend building in Torgsoft:

• do not rush to break the current process before the law is signed and published;

• at the same time, prepare new invoice templates;

• implement control over payments and dates;

• keep traditional certificates where they truly protect the company, its money, and its reputation.

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