Primary documents in inventory accounting for sole proprietorships in 2026

What are primary documents?

In general, primary documents are documents that record the fact that a business transaction took place and serve as the basis for accounting/recordkeeping. The basic definition and requirements for primary documents are set out in Article 9 of the Law of Ukraine “On Accounting and Financial Reporting in Ukraine” No. 996-XIV. Primary documents may be prepared in paper or electronic form (provided that the requirements for electronic documents and signatures are met).

For an FOP, the key point is this: if you are required to keep income and expense records or inventory (stock) records, then your documents must support the corresponding entries. In particular, the Tax Code provides that an FOP on the general taxation system must keep records of income and expenses and have supporting documents (see clause 177.10 of the Tax Code of Ukraine, as explained in information materials of the State Tax Service, for example: STS material).

It is convenient to record transactions electronically: via the STS online services or via the Torgsoft accounting software for retail automation.

Examples of primary documents

The most common examples of primary documents (depending on your activity and processes) include:

• sales notes / goods issue notes (delivery notes);
• goods receipt notes or other documents confirming the receipt of goods;
• certificates of completion / acts of services rendered;
• consignment notes (where logistics require them);
• customs declarations (for import transactions);
• fiscal receipts / settlement documents from RRO/PRRO;
• other documents containing details that identify the parties, date, subject matter, quantity, and value of the transaction.

If an FOP falls under the requirements for inventory (stock) accounting, supporting documents are required to prove proper accounting and the origin of goods. The legal basis is clause 12 of Article 3 of the Law of Ukraine No. 265/95-VR (on RRO), and the procedure for such accounting by FOPs is established by the Ministry of Finance Order No. 496 dated 03.09.2021. The Procedure No. 496 itself specifies which documents may be treated as primary for inventory accounting purposes (delivery notes, transport documents, customs declarations, purchase acts, fiscal/commodity receipts, etc.).

What is not a primary document (or does not replace it)

Some documents may confirm only part of a transaction. For example, a payment instruction/payment order confirms that funds were transferred, but it usually does not replace documents confirming the supply of goods or provision of services (a delivery note, an act, etc.). A bank statement, by contrast, is an important proof of cash flows and is often used as a supporting document for financial transactions (see also your material: about cash flows on an entrepreneur’s accounts).

Standard form for an FOP’s income and expense records (effective in 2026)

For FOPs (and persons engaged in independent professional activity), the standard form for income and expense records and the procedure for maintaining it are approved by the Ministry of Finance Order No. 261 dated 13.05.2021. Recordkeeping may be done in paper or electronic form in accordance with this Procedure.

Practically important rules for maintaining records (summarized, without replacing the wording of the regulation):

1. Entries are made based on primary documents, so that each figure (income/expenses) can be supported by documentation.
2. In the paper format, entries must be legible; corrections should be made in a way that allows the correction and the person who made it to be identified (follow the requirements of Procedure No. 261).
3. In the electronic format, the form may be kept in a spreadsheet (e.g., Excel) or in software/service that generates entries in line with the structure of the standard form.
4. Using government e-services typically requires a qualified electronic signature (QES) / qualified public key certificate (for example, it may be obtained from qualified providers or via banking services, including Privat24).
5. If records are kept electronically, errors are typically corrected by additional entries (to preserve an audit trail), rather than “erasing” history.

Mandatory details (requisites) in primary documents

The mandatory details of primary documents are defined in Part 2 of Article 9 of Law No. 996-XIV: see the law text. In general, a primary document should contain:

• the name of the document (form);
• the date of preparation;
• the name of the entity on whose behalf the document is prepared;
• the content and scope of the transaction, and the unit of measure (where applicable);
• the positions/names of responsible persons;
• a signature or other data enabling identification of the person who participated in the transaction.

Additional details may be added depending on the type of transaction and the requirements of counterparties/control (document number, underlying basis, contract reference, barcodes, etc.). A further reference point is the Regulation on Documentary Support for Accounting Records (Ministry of Finance Order No. 88 dated 24.05.1995).

As for language: for tax control purposes and work with Ukrainian counterparties, it is practically safe to prepare documents in Ukrainian. If a document is received from a non-resident in another language, a translation may be required to support expenses/origin of goods (depending on the specific procedure or request from the controlling authority).

Specifics for an FOP: records, receipts, inventory

1. Cash handling and confirmation of settlements. Unlike many legal entities, an FOP typically does not keep a “cash book” in the classic sense, but must confirm settlement transactions with settlement documents (receipts) in cases where the law requires the use of RRO/PRRO, and must keep such documents for the prescribed periods (see Law No. 265/95-VR).

2. Issuing a receipt to the customer. The entrepreneur issues the customer a settlement document (a fiscal receipt from RRO/PRRO or another document within the permitted operating mode) confirming payment and purchase (see also: commodity receipt or RRO receipt).

3. Who must keep inventory records. The obligation to keep inventory records under clause 12 of Article 3 of Law No. 265/95-VR does not apply to all FOPs. The law provides an exemption for single-tax payers who are not VAT payers, with important exceptions (technically complex household goods subject to warranty repair, medicines/medical devices, jewelry and household items made of precious metals and stones, etc.) — clause 12 of Article 3 of Law No. 265/95-VR. If you fall under the requirement, keep records in accordance with the Ministry of Finance Order No. 496.

Retention periods for primary documents (relevant in 2026)

Tax rules on retention of documents are set out in Article 44 of the Tax Code of Ukraine: the general guideline is at least 1095 days (3 years) for most documents, with exceptions/specific periods for certain cases and document types. See clause 44.3 of the Tax Code (official text: extract of amendments / Tax Code (editions)), as well as the STS explanation of 1095 days as the baseline period: STS material.

In practice, this means:

• keep primary documents, registers, and other supporting materials for at least 3 years (and longer in certain cases if required by the Tax Code or other rules);
• if an audit has started or a dispute is ongoing, it is reasonable to keep the documents until the relevant procedures are completed, even if the baseline period has formally expired;
• for RRO/PRRO there are special requirements for retention of control tapes and electronic documents (see clause 10 of Article 3 of Law No. 265/95-VR: Law No. 265/95-VR).

Storage rules and readiness for an audit

If you are required to keep inventory records, then during an audit the controlling authority may request documents confirming the accounting and origin of goods located at the place of sale (business premises), and you must provide them as of the start of the audit — clause 12 of Article 3 of Law No. 265/95-VR. Procedure No. 496 also directly states that primary documents are an integral part of the records and are provided during an audit by the FOP personally or by the person who actually performs sales/settlement transactions (Order No. 496).

To minimize risks, keep in order:

• a “receipt” file/archive (delivery notes, consignment notes, customs documents, purchase acts);
• a “sales” file/archive (RRO/PRRO receipts, delivery notes/acts where needed, returns);
• internal transfers between outlets/warehouses (if you have more than one place of sale);
• backups of electronic documents and a clear storage structure.

Liability and fines: what you may actually face

1) Inventory without proper records or without documents confirming origin

If a business entity sells goods that are not accounted for in the prescribed manner and/or fails to provide during an audit documents confirming the accounting of goods at the place of sale, a financial sanction applies under Article 20 of Law No. 265/95-VR: in the amount of the value of such goods at selling prices, but not less than 10 non-taxable minimum incomes of citizens. See Article 20 of Law No. 265/95-VR.

2) Failure to keep / improper keeping of income and expense records

Administrative liability for violation of the procedure for keeping income and expense records is provided for by Article 164-1 of the Code of Ukraine on Administrative Offenses: a warning or a fine within the limits established by this article (linked to the non-taxable minimum). Official text: Code of Administrative Offenses, Article 164-1.

3) Failure to ensure retention of documents / failure to provide documents during tax control

The Tax Code provides for a fine for failure to ensure retention of primary documents (and/or failure to provide documents in tax control procedures) — clause 121.1 of Article 121 of the Tax Code. In practical explanations of the STS for a “basic” case, amounts of UAH 1,020 and UAH 2,040 are cited for a repeated violation within a year (see, for example, an STS notice: Regional STS).

Practical takeaway

The legally safe logic is simple: every figure in your records must be supported by a document, and for goods — also by proof of origin and movement of stock if you fall under the inventory recordkeeping requirement. Systematic recordkeeping reduces the risk of fines, simplifies audits, and gives the owner control over profitability and stock levels.

In Torgsoft accounting software, you can generate primary documents, store them electronically, and print them when needed — which is convenient for retail processes and document discipline.