Cash on Delivery via Nova Poshta for Sole Proprietorships: How to Receive Payments, When an ECR/PECR Is Required, and What the State Tax Service Monitors

Cash on delivery is not prohibited for Sole Proprietorships or legal entities. Customers can still pay for parcels upon receipt, including by cash or card through a payment service provider. The restriction concerns something else: a money transfer whose recipient is a Sole Proprietorship, legal entity, or person engaged in independent professional activity cannot be paid out to that recipient in cash as a transfer without opening an account. The funds must be credited to an account. The entrepreneur may then use the money or withdraw cash from their own account under the rules of the bank or other payment service provider.

Whether an ECR/PECR is required for cash on delivery depends not on the name of the payment method, but on who accepts payment from the customer under the agreement and issues the settlement document. If a carrier or courier accepts the cash-on-delivery payment in its own name and issues the customer a settlement document, the State Tax Service allows the seller not to use their own ECR/PECR. However, if the seller conducts the settlement transaction, including accepting card payments through internet acquiring, an ECR/PECR is generally required. A direct transfer by the customer to the seller's current account using IBAN details does not require an ECR/PECR.

What NBU Resolution No. 101 Changed for Cash on Delivery

Resolution No. 101 of the Board of the National Bank of Ukraine, dated August 23, 2024, amended the Instruction on the Organization of Cash Operations by Banks and the Execution of Payment Transactions by Payment Service Providers. It took effect on August 29, 2024.

Following these amendments, a payment service provider or its commercial agent:

• accepts cash from legal entities, Sole Proprietorships, and persons engaged in independent professional activity exclusively for crediting to accounts;

• may accept cash from an individual for a transfer without opening an account, with subsequent cash payout only to another individual who is not a Sole Proprietorship owner or a person engaged in independent professional activity;

• may disburse cash to a Sole Proprietorship owner or legal entity from their own account.

Therefore, claims that entrepreneurs have been «banned from using cash on delivery through Nova Poshta» are incorrect. What is prohibited is paying out a transfer made without opening an account to a business in cash, not cash on delivery itself.

For the customer, essentially nothing changes: they can pay for a parcel using any method supported by the payment service. The restriction applies when funds are paid out to the business.

How Sole Proprietorships and Companies Receive Cash-on-Delivery Payments Through Nova Poshta

NovaPay handles cash-on-delivery payment transactions for Nova Poshta shipments. For Sole Proprietorships and legal entities, the service provides for cash-on-delivery payments to be credited to a business account by bank transfer.

For regular business operations, the contractual arrangements must be properly established. In particular, NovaPay provides for:

• a cash-on-delivery agreement;

• an account to which the funds will be credited;

• a logistics services agreement with Nova Poshta, if required for the applicable cooperation model;

• identification and the Sole Proprietorship or legal entity documents required by the financial institution.

A Sole Proprietorship owner with a NovaPay account can arrange a cash-on-delivery agreement through the app. Legal entities and entrepreneurs receiving payments into another account establish their arrangements according to NovaPay's procedures.

Cash-on-delivery payments can be credited either to a NovaPay account or to another account specified in the agreement. The exact crediting times and fees depend on the current tariff and agreement, so they should be checked immediately before activating the service.

When an Online Store Needs an ECR or PECR

Law No. 265/95-VR requires businesses to process settlement transactions for the sale of goods through an ECR or PECR and provide customers with a settlement document. This also applies to goods ordered or paid for online.

However, not every receipt of money into an account constitutes a settlement transaction.

IBAN Transfers

If an online store provides the customer with full current account details in IBAN format and the customer independently makes a bank transfer to that account, the State Tax Service expressly explains that an ECR/PECR is not used for such a payment.

If the same entrepreneur accepts some payments via IBAN and others in cash, by card, or through internet acquiring, the exemption applies only to IBAN transfers. Other settlement transactions must be fiscalized.

Card Payments and Internet Acquiring

Payment by bank card, POS terminal, or internet acquiring service is a settlement transaction. Sole Proprietorships in single-tax Groups 2–4 and Sole Proprietorships under the general taxation system that conduct such transactions use an ECR or PECR.

A fiscal receipt may be provided to the customer in paper form or in an electronic form permitted by law.

Cash on Delivery Through a Courier or Carrier

The State Tax Service specifically emphasizes that terms such as «cash on delivery», «prepayment», «credit», «deferred payment», or «installment payment» do not themselves determine whether the seller must use an ECR.

What matters is the agreements between the seller and the carrier, courier, freight forwarder, or logistics company, and the role assigned to each party in accepting money from the customer.

If the courier or carrier:

• accepts the cash-on-delivery payment from the customer in its own name;

• issues the customer a settlement document confirming receipt of the money;

• performs these obligations under an agreement,

the State Tax Service considers that the seller is not additionally required to process the same cash-on-delivery payment through their own ECR/PECR.

This is an important rule for online stores: fiscalization should not be duplicated automatically merely because the sale uses cash on delivery. First determine who legally conducts the settlement transaction.

When the Delivery Service Only Transports the Goods

A different situation arises when a freight forwarder or logistics company merely transports the goods under the agreement, does not accept payment for them in its own name, and is not a party to the relevant settlement.

For such arrangements, the State Tax Service considers that the obligation to fiscalize the transaction remains with the seller. The tax authority also notes that issuing the seller's fiscal receipt after dispatching the goods under this model may be regarded as a violation.

Therefore, for an unusual delivery arrangement, it is not enough to rely on the service name shown in the carrier's account dashboard. The agreement and actual movement of money must be examined.

Can a Group 1 Sole Proprietorship Sell Online Without an ECR?

Group 1 single-tax payers are exempt from using an ECR/PECR. However, Group 1 is intended for Sole Proprietorship owners without employees who sell goods at retail from market trading places and/or provide specified household services to individuals.

Therefore, the Group 1 exemption should not be treated as a general basis for operating an online store. In its 2026 clarifications, the State Tax Service expressly points out that sales through online stores, marketplaces, social networks, or arranging delivery may fall outside the activities permitted for Group 1.

What Documents Should the Customer Receive for Cash on Delivery?

The required documents depend on the settlement model.

If the seller uses an ECR/PECR, the customer must receive a proper fiscal settlement document. The form and mandatory details of fiscal receipts are defined by the Regulation approved by Ministry of Finance Order No. 13. The document remains in force, and its current version incorporates amendments to the form and content of settlement documents.

If a courier or carrier accepts cash on delivery in its own name and issues its own settlement document to the customer, the State Tax Service states that the seller must include a delivery note or another document confirming the origin of the goods in the shipment. Where required by law, a properly completed warranty certificate, technical passport, or equivalent document must also accompany the goods.

A financial institution's money transfer document and the seller's fiscal receipt are not the same thing. A NovaPay receipt confirms the relevant payment transaction. If the seller is also required to use an ECR/PECR under the particular arrangement, the payment service receipt does not remove that obligation.

What an Online Store Must Disclose to Customers

Sales through websites, marketplaces, or other remote channels are also subject to electronic commerce and consumer protection legislation.

Before entering into an agreement, customers must have access to information allowing them to understand who they are contracting with and what they are buying. In particular, the law requires appropriate information about the seller, goods, price, payment and delivery terms, and other essential terms of a distance purchase.

Goods subject to warranty requirements must be accompanied by the appropriate warranty documents. Additional requirements concerning labeling, information in Ukrainian, certification, safety, and circulation may apply to particular product categories. These requirements are determined by legislation governing those categories and do not arise merely because cash on delivery is used.

Law of Ukraine No. 1023-XII remains in force in the field of consumer protection. The new Law No. 3153-IX has the status of a law pending entry into force, so its future provisions should not be applied as if they were already effective.

How the State Tax Service Monitors Online Sales

Since March 1, 2025, the State Tax Service has used an additional mechanism to identify persons who systematically sell goods online and receive money transfers for them.

In its official announcement, the State Tax Service states that it receives information from the ECR Data Accounting System, including information concerning:

• individuals who systematically receive payments for sold goods into their personal accounts and effectively conduct business activities without state registration;

• Sole Proprietorships that receive funds into accounts but have no registered ECR/PECR.

However, the mere absence of an ECR/PECR when money is credited to an account does not automatically constitute a violation in every case. For example, the State Tax Service itself confirms that an ECR/PECR is not required for payments made exclusively to a current account via IBAN, while the obligation for courier cash-on-delivery payments depends on the agreement. Therefore, system data may attract the attention of the supervisory authority, but the legality of each transaction must be assessed according to its actual payment model.

The official State Tax Service announcement identifies the ECR Data Accounting System as the source of this monitoring tool. It does not justify claiming that this mechanism provides the tax authority with unrestricted direct access to all citizens' bank accounts.

Who Should Pay Particular Attention to Their Payment Arrangements?

Entrepreneurs whose actual cash flows do not match their agreements and fiscal documents face the greatest risks.

You should review your business arrangements if:

• goods are regularly sold through Instagram, Facebook, Telegram, classified advertising websites, or marketplaces without registering the business activity;

• a Sole Proprietorship accepts card payments or payments through internet acquiring without using an ECR/PECR;

• the seller assumes that all cash-on-delivery payments are automatically exempt from ECR requirements without reviewing the delivery service agreement;

• the logistics company does not participate in settlements under the agreement, but the seller does not issue a receipt;

• payments arrive through different methods, but all are recorded identically as «bank transfers»;

• receipts are issued for incorrect amounts or at a time that does not correspond to the relevant settlement model;

• sales records, bank receipts, shipments, and actual income records consistently fail to match.

Tax Accounting for Cash-on-Delivery Payments

Receiving cash-on-delivery payments into an account does not exempt a business from recording and declaring the income.

For a Sole Proprietorship paying the single tax, the State Tax Service considers the date funds are credited to the account to be the income recognition date for conventional cash-on-delivery payments through a payment system. For example, if goods are dispatched on December 31 and the cash-on-delivery payment reaches the account on January 2, the income is recognized on the date the funds are credited.

Paragraph 292.6 of the Tax Code generally links the income recognition date for single-tax payers to the receipt of monetary funds. Sole Proprietorships paying the single tax, for whom the Code provides the relevant procedure, maintain records of income received in paper or electronic form.

For card acquiring, the State Tax Service applies a different approach: if the transaction is processed with a fiscal receipt, the income recognition date for a single-tax Sole Proprietorship is the date shown on the fiscal receipt, and income is calculated using the full revenue amount, including the bank's commission.

Therefore, cash on delivery, direct IBAN transfers, and internet acquiring payments should not be combined in the records as a single transaction type.

Penalties for Violating ECR/PECR Rules

Under paragraph 1 of Article 17 of Law No. 265/95-VR, financial penalties apply for failure to process a settlement transaction through an ECR/PECR, processing it for less than the full amount, or failing to provide the proper settlement document:

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

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

The temporarily reduced penalties applicable to certain Sole Proprietorships ended on July 31, 2025. Since August 1, 2025, the standard rates of 100% and 150% have applied. Each individual sale without the required ECR/PECR or without issuing a receipt may be treated as a separate violation.

In addition to financial penalties imposed on the business, Article 155-1 of the Code of Ukraine on Administrative Offenses provides for administrative liability for violations of the legally established settlement procedure:

• for persons conducting settlement transactions — from 2 to 5 non-taxable minimum incomes of citizens, equivalent to UAH 34–85;

• for officials — from 5 to 10 non-taxable minimums, equivalent to UAH 85–170;

• for a repeated violation within one year — UAH 85–170 and UAH 170–340, respectively.

Financial penalties under Law No. 265 and administrative fines under the Code of Ukraine on Administrative Offenses have different legal classifications and may be imposed where provided for by law.

How to Organize Online Sales With Cash on Delivery Without Unnecessary Risks

For systematic online store operations, it is advisable to organize the process in the following sequence:

1. Register the business activity. Regular sales of goods for income must be conducted by a registered business entity.

2. Separate payment methods. In internal accounting, distinguish direct IBAN transfers, card acquiring, cash, and cash on delivery through a payment intermediary.

3. Review agreements with the carrier and NovaPay. The agreements should clearly establish who accepts money from the customer and who issues the settlement document.

4. Use a business account for cash on delivery. Cash-on-delivery payments to businesses are credited to an account by bank transfer; NBU rules do not provide for cash payouts of such transfers without an account to Sole Proprietorships and legal entities.

5. Register an ECR/PECR if settlement transactions are conducted. A PECR of the appropriate type may be used for online trading.

6. Configure fiscalization correctly. Do not automatically fiscalize transactions that are not legally classified as settlement transactions, but do not leave card, cash, and other transactions requiring fiscal receipts undocumented.

7. Provide customers with the proper documents. Depending on the payment model, these may include the seller's fiscal receipt, the payment intermediary's settlement document, a delivery note, warranty documents, and other product documents.

8. Reconcile orders, shipments, payments, and income. Website, delivery service, bank account, PECR, and internal inventory records should make it possible to trace every sale.

Online Orders, Nova Poshta, Bank Payments, and PECR in Torgsoft

Torgsoft allows businesses to manage online sales from receiving an order through shipping and payment monitoring. With the relevant additional features, the software supports synchronization with online stores and marketplaces, while unpaid orders, including cash-on-delivery orders, can be imported into the «Remote Customer Order» mode. For certain integrations, an invoice can be generated automatically.

The «Nova Poshta Integration» option allows users to create shipping waybills from delivery notes, send them to Nova Poshta, print documents, and track delivery status directly in Torgsoft. Waybill statuses can be updated manually or automatically on a schedule. This links the goods document to a specific shipment and shows whether the parcel has been dispatched and delivered.

To monitor cashless receipts, Torgsoft provides the additional «Bank Statements» feature, which allows users to import and review money movements from supported banks without constantly switching to online banking. Separately, Torgsoft supports software ECR integration: the settings include an «online trading» PECR type, and the software supports preparing an application for its registration.

Thus, a single accounting workflow can connect an online order, an invoice and delivery note, a Nova Poshta shipment, money movements, and fiscalization of transactions where required. However, the entrepreneur must determine whether a particular transaction must be processed through an ECR/PECR based on the applicable agreement and payment method.

Example of Tax Monitoring of Online Sales

In April 2025, the State Tax Service reported the results of the first weeks of its new monitoring mechanism. According to the agency, during the first 20 days of March alone, tens of thousands of taxpayers and individuals who systematically received funds into personal accounts were identified; in some cases, one individual received hundreds of transfers despite having no state business registration or ECR/PECR. The State Tax Service stated that this monitoring is carried out continuously.

For a legally operating online store, the lesson from this practice is not that every receipt into an account must be fiscalized, but that each payment method should have a clear, documented settlement model.

Official Sources

Law of Ukraine «On the Use of Registrars of Settlement Transactions in Trade, Catering and Services» No. 265/95-VR — Articles 2, 3, 9, and 17.
zakon.rada.gov.ua/go/265/95-вр

Resolution of the Board of the National Bank of Ukraine dated August 23, 2024, No. 101, «On Approval of Amendments to the Instruction on the Organization of Cash Operations by Banks and the Execution of Payment Transactions by Payment Service Providers in Ukraine» — amendments to paragraphs 128 and 140 of Instruction No. 103.
zakon.rada.gov.ua/go/v0101500-24

Tax Code of Ukraine No. 2755-VI — paragraphs 291.4, 291.6, 292.1, 292.6, 296.1, and 296.10.
zakon.rada.gov.ua/go/2755-17

Law of Ukraine «On Electronic Commerce» No. 675-VIII — Articles 7, 11, and 13.
zakon.rada.gov.ua/go/675-19

Law of Ukraine «On Consumer Protection» No. 1023-XII — Articles 8, 9, 13, and 15.
zakon.rada.gov.ua/go/1023-12

Order of the Ministry of Finance of Ukraine dated January 21, 2016, No. 13, «On Approval of the Regulation on the Form and Content of Settlement Documents/Electronic Settlement Documents…» — Regulation on the form and content of settlement documents.
zakon.rada.gov.ua/go/z0220-16

Code of Ukraine on Administrative Offenses No. 8073-X — Article 155-1.
zakon.rada.gov.ua/laws/show/80731-10

State Tax Service: «The State Tax Service Has Obtained a New Tool for Monitoring Online Sales» — official announcement dated April 2, 2025.
tax.gov.ua — online sales monitoring

State Tax Service Public Information Resource: ECR/PECR Use When Selling Goods Cash on Delivery Through Delivery Services.
zir.tax.gov.ua — cash on delivery and delivery services

State Tax Service Public Information Resource: ECR/PECR Use for Online Payments Using IBAN Details.
zir.tax.gov.ua — IBAN payments

NovaPay: Crediting Cash-on-Delivery Payments to Accounts of Sole Proprietorships and Legal Entities.
novapay.ua — cash-on-delivery payments to accounts