NovaPay limits for sole proprietors from September 1, 2026: who they apply to, what amounts and how to undergo financial monitoring

From September 1, 2026, NovaPay announced monthly transfer limits for certain categories of Sole Proprietorships: for Group 1 — up to UAH 600,000 per month, and for Groups 2 and 3 — up to UAH 3,000,000 per month. This primarily concerns newly registered Sole Proprietorships and entrepreneurs who had no active transactions for a certain period and then resumed operations. These are not new tax limits, a prohibition on receiving income, or an automatic blocking of all Sole Proprietorship accounts. NovaPay communicated the exact amounts to clients in separate notifications; these Memorandum-based limits have not yet been published as a separate public document on NovaPay's official website. («Debit-Credit» - Accounting News)

The restrictions are related to the updated Memorandum on Ensuring Transparency in the Payment Services Market. The Memorandum itself is not a law and does not establish tax penalties. It provides for risk-based monitoring: standard restrictions may not apply to businesses with transparent operations, confirmed income and paid taxes, while if an established limit does not meet the actual needs of the business, the entrepreneur may request an increase by providing documentary evidence of the volume and economic substance of the transactions. (Association of Ukrainian Banks)

Why NovaPay introduced new limits for Sole Proprietorships

On May 14, 2026, financial market participants signed an updated version of the Memorandum on Ensuring Transparency in the Payment Services Market. The document is open for voluntary accession by banks and other payment service providers. The Association of Ukrainian Banks explicitly states that the Memorandum does not create new statutory restrictions and does not change financial monitoring requirements: it is an agreed market approach to assessing the risk of clients and their transactions. (Association of Ukrainian Banks)

Therefore, the UAH 600,000 or UAH 3,000,000 limit should not be regarded as a state-imposed threshold for the operation of a Sole Proprietorship. It is an operational restriction applied by a payment service provider within its own risk management system.

Law No. 361-IX requires financial institutions to apply a risk-based approach and conduct proper customer due diligence. This includes not only identifying the entrepreneur, but also understanding the purpose of the business relationship, continuously monitoring transactions, and checking whether they correspond to the information known to the institution about the client's activities, risk profile and, where necessary, source of funds. For non-bank financial institutions, these rules are detailed in NBU Regulation No. 107. (Ukrainian Legislation)

Who is affected by NovaPay limits

NovaPay's notification, published by professional media, identifies two main categories:

• newly registered Sole Proprietorships;

• inactive Sole Proprietorships that resume operations.

The Memorandum itself formulates the rules more precisely: the restrictions are intended for higher-risk clients, including newly registered and inactive Sole Proprietorships that have resumed operations. For new and reactivated Sole Proprietorships, the document separately mentions a period of up to six months and the need for enhanced review of business activity depending on the level of risk.

For other active Sole Proprietorships, the Memorandum provides for monitoring under the specific payment service provider's own risk-based approach rather than automatically applying the same limit to every entrepreneur.

What limits apply and what comes next

The Memorandum establishes the second stage six months after the amendments were signed, i.e. from November 14, 2026. The same date has already been officially applied, for example, by Oschadbank: from August 15 — UAH 600,000/3,000,000, and from November 14 — UAH 400,000/1,000,000 for the relevant categories of newly registered or reactivated Sole Proprietorships. This is a practical example of implementing the provisions of the same Memorandum.

For NovaPay clients, the specific implementation of the second stage should be assessed according to the rules and notifications of the payment service provider itself, since the Memorandum allows each institution to implement a risk-based approach in accordance with its own policies.

What exactly is limited: income, incoming funds or transfers

The Memorandum specifically refers to transfers from Sole Proprietorship accounts within Ukraine to the accounts of other counterparties, taking into account the risk-based approach. Therefore, the figures of UAH 600,000 and UAH 3,000,000 are not the permitted monthly income of an entrepreneur and do not determine how much goods or services a Sole Proprietorship may sell.

Depending on its own policy, a payment service provider may also exclude certain low-risk transactions from such a limit, for example tax or utility payments. This is not a general statutory exemption: the specific procedure is determined by the financial institution itself.

NovaPay also has standard technical and operational limits for Sole Proprietorship payment cards. The official website contains the version of these card limits effective from August 12, 2026. This is a different type of restriction and should not be confused with the limits established under the Memorandum. (NovaPay)

NovaPay limits do not replace annual single tax income limits

For Sole Proprietorships using the simplified taxation system, the main tax threshold remains the annual income limit established by the Tax Code. The amount of the limit depends on the minimum wage established as of January 1 of the respective year. In 2026, the minimum wage is UAH 8,647. (Ukrainian Legislation)

These amounts are confirmed by the State Tax Service of Ukraine. Therefore, for example, the technical ability to transfer up to UAH 600,000 per month through NovaPay does not mean that a Group 1 Sole Proprietorship may receive UAH 7.2 million in business income per year and remain in Group 1. (dp.tax.gov.ua)

If a Sole Proprietorship in Groups 1—3 exceeds the applicable tax income limit, a 15% single tax rate applies to the excess amount, followed by the rules on switching to another group or paying other taxes depending on the group and circumstances. These are consequences of the Tax Code, not NovaPay rules. (State Tax Service of Ukraine)

Which transactions may attract additional financial monitoring attention

The updated Memorandum contains specific indicators that payment service providers may take into account when monitoring Sole Proprietorship accounts. These include:

• a sharp increase in the number of account transactions involving different individuals or Sole Proprietorships;

• an account balance close to zero both at the beginning and at the end of the day;

• an atypical twofold or greater increase in the number of incoming transactions from individuals, if this does not correspond to the nature of the business;

• splitting transfers, including transactions involving round amounts from one counterparty or in favour of one counterparty during a month, if this cannot be explained by the business model.

This does not mean that the presence of one such indicator automatically proves a violation. The law requires clients and transactions to be assessed using a risk-based approach, taking into account the nature of the business, transaction volumes, information about the client and the economic substance of payments. (Ukrainian Legislation)

For this reason, statements such as «the transaction does not correspond to the KVED activity code — the account will be blocked» should not be presented as official NovaPay criteria. The Memorandum does not establish such an automatic rule. At the same time, registered types of activity, contracts, the nature of sales and cash flows should be consistent with one another, since the financial institution must understand the client's actual business activity.

What documents may be required to increase a NovaPay limit

The Memorandum does not establish a universal closed list of documents that every Sole Proprietorship must submit to NovaPay in every case. It requires documentary confirmation of the need to increase the limit and the ability to conduct transactions in the declared amounts. Seasonality of the business and the need for significant capital expenditure are expressly mentioned as examples.

Depending on the specific activity, it is advisable to have a set of documents that makes it possible to trace a business transaction from a purchase or contract through to payment:

• contracts with buyers, customers and suppliers;

• invoices, certificates of completed works, delivery notes and goods invoices;

• documents confirming the purchase of goods and formation of inventory balances;

• tax returns and other documents confirming declared turnover;

• statements from business accounts;

• documents related to major purchases of equipment, rent, investments or other significant expenses;

• explanations regarding the type of activity, seasonality, planned turnover and the economic substance of specific payments.

This is an indicative supporting document package, not a mandatory list approved by NovaPay. The scope of documents depends on the reason for reviewing the limit and the nature of the transaction.

What to do if actual business turnover exceeds the established limit

An entrepreneur may contact the payment service provider and request an increase in the established limit. The Memorandum explicitly provides for this possibility if the need for a higher limit and the business's actual ability to conduct transactions in the declared amounts are supported by documents.

Before submitting such a request, it is advisable to prepare not only evidence of the source of funds but also a clear link between payments and business activity: who is paying, for what goods or services, under which contract or invoice, why this particular transaction volume has arisen, and to whom the funds are subsequently transferred.

Reaching NovaPay's internal limit does not in itself result in a separate state fine for a Sole Proprietorship. The Memorandum is not a regulatory legal act. The consequence may be the need for additional approval of a transaction, a review of the limit, or other financial monitoring procedures in accordance with the law and the payment service provider's rules. (Association of Ukrainian Banks)

ECR/pECR when paying through NovaPay: transfer limits do not change the rules

The introduction of the new limits does not cancel or change the rules for using ECR/pECR. For the sale of goods, it is particularly important to distinguish a standard bank transfer from a payment made through a non-bank payment service provider.

The current Knowledge Base of the State Tax Service of Ukraine states that if goods are shipped by a forwarding company and the buyer makes a payment through a non-bank payment service provider to the seller's payment account opened with that provider, the seller must use an ECR/pECR and issue a fiscal receipt with the payment method specified as «cashless». (ZIR)

A different situation is a standard transfer through a banking institution from the buyer's current bank account to the seller's current bank account using IBAN details. The State Tax Service of Ukraine states that in this case an ECR/pECR is not required. The mere presence of an IBAN does not mean that the account is necessarily opened with a bank: NovaPay is a non-bank payment service provider. (ZIR)

For cash on delivery, the contractual model must also be taken into account: who actually accepts the money from the buyer and who issues the settlement document when the goods are handed over. In its clarification regarding NovaPay, the State Tax Service of Ukraine indicated that under a model where the courier accepts the cash-on-delivery payment on its own behalf and issues a settlement document directly to the buyer when handing over the shipment, the seller's obligation to use its own ECR/pECR may differ. Therefore, for cash-on-delivery transactions, the current agreement with the carrier and payment service should be assessed rather than only the method by which the funds are credited. (od.tax.gov.ua)

For services, there is a separate exemption: paragraph 14 of Article 9 of Law No. 265 allows an ECR/pECR not to be used if payments for services are made exclusively through remote banking systems and/or money transfer services. This special rule applies specifically to services and does not automatically extend to the sale of goods. (State Tax Service of Ukraine)

How to calculate Sole Proprietorship income if the payment service charges a fee

The NovaPay transfer limit does not determine the amount of taxable income of a Sole Proprietorship. Income must be calculated in accordance with Article 292 of the Tax Code depending on the form of payment.

In particular, for payments made through payment terminals, the State Tax Service of Ukraine takes the position that if a payment processing fee is deducted from revenue, the income of a Sole Proprietorship paying single tax is the full amount of revenue including the deducted fee, rather than only the «net» amount remaining after the fee. Therefore, relying exclusively on the net amount credited to the account may be risky. (zak.tax.gov.ua)

For example, if a buyer paid UAH 10,000 for goods, the payment intermediary deducted a UAH 200 fee and actually credited UAH 9,800 to the entrepreneur, then for transactions covered by the approach described by the State Tax Service of Ukraine, the business income is UAH 10,000 rather than UAH 9,800.

How Torgsoft can help confirm sales, payments and shipments for NovaPay financial monitoring

Torgsoft allows you to build a documentary chain from a sale through to receipt of payment. The software allows you to work with invoices and delivery notes, create a delivery note for a specific invoice and link a received payment to the corresponding unpaid invoice. Payment search filters are available by period, accounting centre, current account and outstanding debt amount. This helps confirm that a specific incoming payment is linked to an actual sale of goods or an order.

The additional «Bank Statements for Accounts» feature allows Torgsoft to receive information about incoming payments for supported bank accounts and link a payment to an invoice. The software documentation specifically mentions integration with Privat24, monobank and UKRSIBBANK. Direct import of statements specifically from a NovaPay payment account is not confirmed in the available Torgsoft documentation, so this functionality should not be considered available without additional verification. At the same time, Torgsoft allows incoming payments to a current account to be recorded with the payer, invoice, amount and payment purpose specified.

For online sales and shipments, the «Nova Poshta Integration» feature is useful: Torgsoft allows you to create a Nova Poshta consignment note from a delivery note, print it and track the delivery status. This allows the entrepreneur to maintain the «invoice — delivery note — shipment — payment» link in the accounting system, which significantly simplifies preparation of documents at the request of a financial institution.

What an entrepreneur should check

Before processing large turnover through NovaPay, it is advisable to compare actual business activity with registration and tax data, check the annual income limit for the applicable single tax group, systematise contracts and primary documents, separately monitor payments and refunds, retain account statements and, when selling goods, correctly determine the time and method of fiscalisation.

If a business is seasonal, plans a major purchase of goods or equipment, or expects another sharp increase in turnover, documents confirming such growth should preferably be prepared before the relevant payments are made. The Memorandum explicitly identifies seasonality and significant capital expenditure as examples of grounds that may justify the need to increase the limit.

Official sources

Memorandum on Ensuring Transparency in the Payment Services Market, version dated 14.05.2026. Key provisions: risk-based approach to Sole Proprietorships; limits of UAH 600,000/3,000,000 after three months and UAH 400,000/1,000,000 after six months; the possibility of documenting the need to increase the limit; risk indicators. Official text of the Memorandum on the Association of Ukrainian Banks website

Law of Ukraine «On Prevention and Counteraction to Legalisation (Laundering) of Proceeds...» dated 06.12.2019 No. 361-IX. Key provisions: Article 7 — risk-based approach; Article 11 — customer due diligence. The law is effective as amended from 01.01.2026. (Ukrainian Legislation) Law No. 361-IX on the website of the Verkhovna Rada of Ukraine

Resolution of the Board of the National Bank of Ukraine dated 28.07.2020 No. 107 «On Approval of the Regulation on Financial Monitoring by Institutions». Regulates financial monitoring by non-bank institutions; the document is currently in force. (Ukrainian Legislation) NBU Resolution No. 107 on the website of the Verkhovna Rada of Ukraine

Tax Code of Ukraine dated 02.12.2010 No. 2755-VI. Key provisions: paragraph 291.4 — conditions and maximum income thresholds for single tax groups; Article 292 — determination of income; paragraph 293.4 — the 15% rate for specified income, including the amount exceeding the limit. (State Tax Service of Ukraine) Tax Code of Ukraine on the website of the Verkhovna Rada of Ukraine

Law of Ukraine «On the State Budget of Ukraine for 2026» dated 03.12.2025 No. 4695-IX. Article 8 — minimum wage of UAH 8,647 from January 1, 2026, which is used to calculate the annual income limits for single tax payers. (Ukrainian Legislation) Law No. 4695-IX on the website of the Verkhovna Rada of Ukraine

Law of Ukraine «On the Use of Registrars of Settlement Operations in Trade, Catering and Services» dated 06.07.1995 No. 265/95-VR. Key provisions: Article 3 — obligations when conducting settlement transactions; Article 9 — cases where ECR/pECR are not required, including the special provision of paragraph 14 regarding payments for services. Law No. 265/95-VR on the website of the Verkhovna Rada of Ukraine

State Tax Service of Ukraine, Public Information and Reference Resource. The current clarification regarding payment for goods through a non-bank payment service provider requires the use of ECR/pECR. Clarification of the State Tax Service of Ukraine regarding a non-bank payment service provider

NovaPay — official information on payment card limits for business entities. Separate card limits have been effective since 12.08.2026 and are not the same as the limits established under the Memorandum. Official NovaPay page with business card limits