Fiscalization of Prepayments and Cash on Delivery in an Online Store: ECR/PECR, Nova Poshta, NovaPay, and Ukrposhta

For an online store, the obligation to use an ECR/PECR depends not on the payment label itself — «prepayment», «postpayment», «cash on delivery», or «deferred payment» — but on who actually accepts the buyer’s money and how the payment is made. Card payments on the website, through online acquiring, or through another payment service in favor of the seller generally require an ECR/PECR. A direct transfer by the buyer to the seller’s current bank account using IBAN details may be made without an ECR/PECR. For cash on delivery through a delivery service, the contract terms are decisive: if the carrier or courier accepts the payment in its own name and issues a payment document to the buyer, the seller does not separately process that payment through its own ECR/PECR.

If the buyer pays in installments, each installment that constitutes a settlement transaction — for example, a card or cash payment — must be documented with a separate fiscal receipt. For distance sales, the receipt may be provided in paper or electronic form; the State Tax Service (STS) permits it to be provided during payment or no later than when the buyer receives the goods. If a sale has already been fiscalized but the buyer does not collect the parcel, the seller processes a return after receiving documentary confirmation from the delivery service. Failure to properly register a settlement transaction or issue a receipt is subject to financial penalties of 100% of the sale value for the first violation and 150% for each subsequent violation.

Which Online Store Payments Require an ECR/PECR?

Law No. 265/95-VR requires settlement transactions to be processed through an ECR or PECR for the full amount and requires the buyer to be provided with a payment document in the prescribed form. This requirement expressly applies to goods ordered or paid for online.

For common payment methods, the rules are as follows:

IBAN Does Not Always Mean an ECR Exemption

It is important to distinguish a current bank account from a payment account held with a non-bank payment service provider. The STS explains that if the buyer receives the seller’s current bank account details in IBAN format and independently transfers funds through a bank, a bank cash desk, or online banking, an ECR/PECR is not required.

However, if the seller provides the details of a payment account opened with a non-bank payment service provider, or payment card details, the use of IBAN format alone does not create such an exemption.

Separately, the Tax Code exempts first-group single-tax payers from using an ECR/PECR. However, the first group is subject to its own restrictions on permitted business activities, so this exemption cannot automatically be applied to every online store.

How to Process Full Prepayment

If the buyer pays the full amount by card on the website, through online acquiring, or by another method that constitutes a settlement transaction, the seller must use an ECR/PECR and provide a fiscal receipt. A receipt issued by a bank, acquiring provider, or payment service does not replace the seller’s fiscal receipt.

For distance selling, Law No. 265 does not specify a separate number of minutes or hours between payment and fiscalization. According to the STS, the receipt must be provided to the buyer during the distance payment transaction or no later than when the goods are received. If the seller receives information about online acquiring payments through a bank statement, the STS permits fiscalization no later than the next business day based on that statement, provided that the chronological order of transactions is maintained and, in any case, before the goods are handed over.

If the entire payment is made by direct bank transfer to the seller’s current account using IBAN details and qualifies for the banking transaction exemption, a fiscal receipt is not required for that payment. Nevertheless, the buyer must still be provided with documents confirming the electronic transaction and the sale of goods in accordance with e-commerce and consumer protection legislation.

Prepayment in Installments: How Many Receipts Are Required?

If the buyer pays in several installments — for example, makes an advance payment, then another partial payment, and finally pays the remaining balance — the STS requires a separate fiscal receipt for each payment installment if that installment is paid in cash or by payment card.

For such transactions, the STS PECR provides the following payment terms:

• «Prepayment» — indicates the amount of the first partial payment;

• «Subsequent Payment» — indicates the amounts previously received, the current payment, and the fiscal number of the prepayment receipt;

• «Final Settlement» — indicates the payments previously received, the final payment amount, and the fiscal number of the prepayment receipt.

Therefore, the legal approach is not to «combine» the advance payment and final payment into a single receipt. Each actual settlement transaction is documented separately, and subsequent receipts must maintain a link to previous payments.

If One Payment Was Made via IBAN and Another by Card or Cash

The STS separately addresses mixed payment arrangements. For example, a buyer first transfers UAH 1,000 to the seller’s current bank account using IBAN details and pays the remaining amount in cash. The first bank payment may not require processing through an ECR/PECR, but a fiscal receipt is required for the cash received. The receipt must also reflect information about the payment received earlier.

Cash on Delivery Through a Delivery Service: The Contract Is Decisive

There is no universal rule stating that a fiscal receipt must «always be issued when dispatching goods» or that «the postal operator always issues the receipt». The STS explicitly states that the seller’s obligations depend on the terms of contracts with the carrier, courier, freight forwarder, logistics company, and payment intermediary.

Option 1. The Carrier or Courier Accepts Cash on Delivery in Its Own Name

If, under the contract, the carrier or courier:

• hands the parcel over to the buyer;

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

• issues the buyer a payment document confirming receipt of the funds;

• then transfers the amount due to the seller,

the STS considers that the seller is not required to additionally process this cash-on-delivery payment through its own ECR/PECR. The seller includes an outgoing invoice or another document confirming the origin of the goods in the parcel. For goods requiring warranty documentation by law, a warranty certificate, technical passport, or equivalent document must also be included.

If part of the purchase price was paid to the seller in advance by card, the seller fiscalizes that prepayment under the general rules. The cash-on-delivery payment accepted by the carrier in its own name under the relevant contract and confirmed by its own payment document does not require a second receipt from the seller merely because the funds are subsequently transferred to the seller.

Option 2. The Logistics Company Only Transports the Goods

The STS separately describes a model in which the freight forwarder or logistics company:

• is not a courier or carrier within the meaning of the relevant legal relationship;

• is not a party to the sales agreement;

• does not accept cash-on-delivery payments;

• only arranges delivery;

• while the funds are subsequently transferred to the seller by a separate bank or non-bank financial intermediary.

For this model, the STS requires a fiscal receipt to be generated before the goods are dispatched and placed inside the parcel or provided to the buyer electronically before or when the goods are handed over to the freight forwarder. In its explanation of this scenario, the STS specifies the payment term «credit» or «deferred payment» and a non-cash payment method. The subsequent transfer of funds from the financial intermediary to the seller does not need to be fiscalized again.

This is why, before configuring receipts for cash-on-delivery transactions, a business owner needs to check the contract rather than the promotional name of the delivery service: who accepts the money, in whose name, what document the buyer receives, and what role the carrier plays in the settlement.

Cash on Delivery Through Nova Poshta and NovaPay

According to Nova Poshta’s public description of its contractual cash-on-delivery service for businesses, the buyer pays for the goods upon receipt, after which the funds are transferred to the seller. Business customers also receive registers of accepted payments containing the consignment note number, payer, amount, and payment date. NovaPay handles the financial component of cash-on-delivery transactions.

However, the mere presence of the words «cash on delivery» or «NovaPay» on a consignment note is not sufficient grounds to automatically determine ECR requirements. You must compare your specific contract with the criteria set out by the STS in its Tax Knowledge Base (ZIR), response No. 40693: whether the carrier or courier accepts the cash-on-delivery payment in its own name and whether the buyer receives the corresponding payment document.

This arrangement should not be confused with a situation in which the buyer pays the seller before dispatch through NovaPay as a regular payment service or online acquiring provider. For such online payments, the STS includes NovaPay among examples of non-cash payment methods that must be reflected in the seller’s fiscal receipt.

Cash on Delivery Through Ukrposhta

Ukrposhta offers a separate payment service called «Cash-on-Delivery Transfer»: the buyer pays for the goods upon receipt, and the funds are transferred to the recipient. The current procedure for this payment service was approved by an internal order of Ukrposhta JSC and regulates the acceptance and transfer of funds without opening an account.

For business customers, the specific contract and payment acceptance arrangement must again be considered. If the terms correspond to the STS model in which the operator or carrier accepts cash on delivery in its own name and issues a payment document to the buyer, the seller does not duplicate this payment with its own fiscal receipt. If the actual arrangement differs, the corresponding seller fiscalization procedure applies.

What Information Must an Online Store Fiscal Receipt Contain?

The fiscal cash receipt form No. FCR-1 and its mandatory details are established by the Regulation approved by Ministry of Finance Order No. 13. The seller must ensure that the receipt contains all mandatory details relevant to the specific transaction, including information about the business entity and business location, product name and quantity, price, applicable tax details, total amount, transaction date and time, receipt number, and fiscal number.

It is particularly important to indicate the payment method correctly. Under the current receipt format:

• line 18 specifies the payment form — «CASH», «NON-CASH», or «OTHER», the amount paid using that form, and the currency;

• line 19 specifies the actual payment instrument used: card, online acquiring, online banking, QR-code transfer, a specific payment service, etc.;

• if several payment forms or instruments are used, the corresponding lines are repeated.

For example, when a customer pays by card on the website, the STS recommends specifying a non-cash payment form and the payment instrument «Online Acquiring» or «Online Card Payment». For a payment through NovaPay, the STS permits the name of the relevant payment service to be indicated as the payment instrument.

Contract terms such as «credit», «deferred payment», or «cash on delivery» must not replace information about the actual payment form and instrument where the receipt format requires the actual settlement method to be stated.

Electronic or Paper Receipt

Paper and electronic fiscal receipts have equal legal status. Law No. 265 permits, among other options:

• printing the receipt;

• displaying a QR code that allows the buyer to identify the payment document;

• sending the electronic payment document to a phone number or email address provided by the buyer.

Therefore, an online store does not necessarily have to include a paper receipt in every parcel if the lawful transaction model allows an electronic receipt and it is provided to the buyer on time. However, for the specific cash-on-delivery scenario involving a freight forwarder, the STS explicitly requires the receipt to be generated before dispatch, while allowing it either to be placed in the parcel or sent to the buyer.

What to Do If the Buyer Does Not Collect the Parcel

The procedure depends on whether the seller generated its fiscal receipt before dispatch.

If the seller fiscalized the sale but the buyer refused the parcel or never received it, the seller must obtain documentary confirmation of the return from the delivery service. The return transaction is then processed through the ECR/PECR based on the delivery service document and the original fiscal receipt, which must allow the goods to be identified. The STS states that this transaction must be processed on the day the supporting documents are received or, if they arrive after the end of the working day, with consideration for the business owner’s operating hours.

If the buyer did not pay any money and the seller is not refunding any funds, no cash disbursement statement is prepared. Recording the return of goods in inventory and refunding money to a buyer are two different transactions.

If money is actually refunded to the buyer, the disbursement must be registered through the ECR/PECR using the appropriate refund transaction. If the actual refund exceeds UAH 100, a cash disbursement statement must be prepared. It must contain details of the buyer’s identity document, information about the goods, the refund amount, and the number, date, and time of the original payment document. Such statements must be retained for three years.

Which Documents Should Be Retained for Prepayments and Cash on Delivery?

Online sales involving delivery should have a documented sequence of transactions. Depending on the arrangement, this may include:

• the buyer’s order or invoice;

• proof of prepayment;

• fiscal receipts and their fiscal numbers;

• an outgoing invoice;

• a consignment note or another delivery service document;

• the contract with the carrier, courier, or logistics company;

• the contract with the bank or payment service;

• cash-on-delivery payment and transfer registers provided by the operator;

• bank statements;

• confirmation of delivery or return of the parcel;

• refund documents;

• a warranty certificate, technical passport, or other mandatory documents for goods for which they are required by law.

These documents are important not only for confirming income and the movement of goods. The contract with the postal or payment operator is what makes it possible to determine who must fiscalize the cash-on-delivery payment.

Inventory Accounting for Sole Proprietorships

Separately from payment fiscalization, Law No. 265 requires certain categories of Sole Proprietorships to maintain inventory records. The procedure is established by Ministry of Finance Order No. 496: information about goods received and disposed of is entered into the Inventory Accounting Form based on primary documents, and receipt of goods must be recorded before they are offered for sale.

This requirement does not apply to Sole Proprietorships that pay single tax and are not VAT payers, except for entrepreneurs selling technically complex household goods subject to warranty repair, medicines and medical devices, or jewelry and household items made of precious metals and gemstones. Procedure No. 496 also applies to Sole Proprietorships under the general taxation system and the relevant VAT-paying Sole Proprietorships.

Documents confirming the origin of goods may include invoices, transport documents, customs declarations, purchase certificates, fiscal and sales receipts, and other primary documents that allow identification of the supplier, recipient, goods, quantity, and value.

Penalties for Violations Involving Prepayment and Cash-on-Delivery Fiscalization

Under paragraph 1 of Article 17 of Law No. 265, financial penalties apply, in particular, when a settlement transaction:

• is carried out without an ECR/PECR when its use is mandatory;

• is processed for less than the full amount;

• is carried out without providing the buyer with the required payment document.

The penalties are:

The reduced rates of 25% and 50%, which previously applied to certain Sole Proprietorships paying single tax, are no longer applicable: since August 1, 2025, the full penalties of 100% and 150% have been in effect.

In addition to financial penalties imposed on the business entity, Article 155-1 of the Code of Ukraine on Administrative Offenses establishes administrative liability for violating the legally prescribed settlement procedure. For persons who directly conduct settlement transactions, the fine ranges from two to five non-taxable minimum incomes of citizens; for officials, from five to ten. If a similar administrative offense is repeated within one year, the respective fines increase to five to ten and ten to twenty non-taxable minimum incomes.

Example from STS Practice

In its Tax Knowledge Base response No. 40693, the STS examines two cash-on-delivery arrangements that appear similar.

In the first, the goods are delivered by a freight forwarder who does not participate in the payment transaction. Under this model, the STS requires the seller to issue a receipt before dispatch. In the second, the courier or carrier accepts the cash-on-delivery payment directly from the buyer under the contract and issues a payment document. In this case, the seller is not required to fiscalize the cash-on-delivery payment again and instead includes an outgoing invoice and other mandatory product documents in the parcel.

This example shows why the same «cash on delivery» label used by two online stores may have different ECR/PECR implications.

ECR/PECR, Prepayment, and Cash on Delivery in Torgsoft: Invoices, Fiscal Receipts, and Delivery Tracking

For online sales in Torgsoft, transactions can be managed through the invoicing-based sales mode: create a customer invoice, record a prepayment, generate an outgoing invoice, and link it to the customer invoice. In the prepayments section, the software records prepayments received and refunded; for transactions involving connected fiscal equipment, it supports generating a fiscal prepayment receipt.

For Nova Poshta, Torgsoft supports cash-on-delivery transactions in outgoing invoices and allows shipments to be filtered by the following statuses: «Cash on Delivery», «Payment Expected», «Payment Arrived», and «Payment Received». This makes it possible to distinguish between dispatching goods, the buyer receiving the parcel, and the subsequent receipt of the cash-on-delivery payment. For Ukrposhta, the software supports creating consignment notes, printing shipping labels, tracking shipments, and automatically updating their statuses in bulk.

In addition, Torgsoft provides a PECR module and fiscal receipt analytics. You can monitor the document type, date and time, fiscal number, associated sale, return or invoice, online/offline mode, and whether the document has been registered on the fiscal server. Bank statements can be used to match incoming payments with invoices. These features help establish a unified process of «order — payment — receipt — dispatch — consignment note — cash on delivery or return». However, the selected fiscalization arrangement must comply with the business owner’s actual contracts with the bank, payment service, and delivery company.

How to Organize Fiscalization of Online Sales

Before launching or changing a payment arrangement, it is worth documenting the following for each sales method:

1. Who receives the money directly from the buyer.

2. Whether the payment is a direct bank transfer to a current account using IBAN details or a card/payment service transaction.

3. Who issues the payment document to the buyer for cash on delivery.

4. What role the delivery service performs under the contract — carrier/courier or freight forwarder only.

5. When fiscal receipts are generated for prepayment, subsequent payments, and final settlement.

6. How the buyer receives an electronic or paper receipt.

7. How the return of an undelivered parcel is confirmed.

8. How consignment notes, cash-on-delivery registers, bank statements, invoices, outgoing invoices, and fiscal receipts are reconciled.

For cash on delivery through a specific operator, the contract remains the key document. If its terms do not clearly establish who participates in the settlement and who issues the payment document to the buyer, it is advisable to obtain an individual tax consultation specifically addressing that contractual arrangement.

Official Sources

Law of Ukraine «On the Use of Registrars of Settlement Transactions in Trade, Catering, and Services» dated July 6, 1995, No. 265/95-VR — Articles 2, 3, 9, 17, and 26. Defines settlement transactions, the obligation to use an ECR/PECR, exemptions, and financial liability.
Law No. 265/95-VR on the website of the Verkhovna Rada of Ukraine

Law of Ukraine «On Consumer Rights Protection» dated May 12, 1991, No. 1023-XII — Article 8, particularly part eleven concerning payment documents and when they must be provided. The law remains in force; Law No. 3153-IX, which is intended to replace it, has not yet entered into force.
Law No. 1023-XII on the website of the Verkhovna Rada of Ukraine

Law of Ukraine «On Electronic Commerce» dated September 3, 2015, No. 675-VIII — Articles 11 and 13 concerning electronic contracts, confirmation of electronic transactions, and payment documents.
Law No. 675-VIII on the website of the Verkhovna Rada of Ukraine

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 Payment Documents/Electronic Payment Documents…» — Section II, Form No. FCR-1, mandatory details, payment forms and instruments.
Ministry of Finance Order No. 13 on the website of the Verkhovna Rada of Ukraine

Order of the Ministry of Finance of Ukraine dated June 14, 2016, No. 547 «On Approval of Procedures for Registering Registrars of Settlement Transactions and Settlement Transaction Record Books» — Section III, including the rules for processing returns and preparing a statement when refunding more than UAH 100.
Ministry of Finance Order No. 547 on the website of the Verkhovna Rada of Ukraine

Order of the Ministry of Finance of Ukraine dated June 23, 2020, No. 317 — procedure for registering and using software ECRs.
Ministry of Finance Order No. 317 on the website of the Verkhovna Rada of Ukraine

Order of the Ministry of Finance of Ukraine dated September 3, 2021, No. 496 «On Approval of the Procedure for Maintaining Inventory Records by Sole Proprietorships, Including Single-Tax Payers» — Sections I–II and the Inventory Accounting Form.
Ministry of Finance Order No. 496 on the website of the Verkhovna Rada of Ukraine

Tax Code of Ukraine No. 2755-VI — paragraph 296.10 of Article 296 concerning the exemption of first-group single-tax payers from using an ECR/PECR.
Tax Code of Ukraine on the website of the Verkhovna Rada of Ukraine

STS Tax Knowledge Base (ZIR), Response No. 40693 — use of ECR/PECR for cash on delivery and the distinction between delivery by a freight forwarder and collection of cash-on-delivery payments by a courier/carrier.
STS guidance on cash on delivery and delivery services

STS Tax Knowledge Base (ZIR), Response No. 41509 — partial payments, prepayments, subsequent payments, and final settlement.
STS guidance on paying for goods in multiple installments

STS Tax Knowledge Base (ZIR), Responses No. 42314 and No. 43434 — payments through online banking using current bank account IBAN details and the distinction from a payment account held with a non-bank provider.

STS guidance dated August 11, 2026 — procedure for processing the return of a parcel not collected by the buyer through an ECR/PECR.
STS guidance «The Buyer Did Not Collect the Goods: When Should a Return Be Processed Through an ECR/PECR?»

Official Nova Poshta/NovaPay Cash-on-Delivery Terms — procedure for accepting cash-on-delivery payments, transferring funds to the seller, and generating payment registers.
Nova Poshta cash-on-delivery agreement for businesses

Ukrposhta JSC, Procedure for Providing the «Cash-on-Delivery Transfer» Payment Service — procedure for accepting and transferring funds without opening an account.
Ukrposhta «Cash-on-Delivery Transfer» procedure