Cash on Delivery via Nova Poshta: Receipts, Sole Proprietor Income, and Accounting in Torgsoft

A sole proprietor (FOP) selling goods in Ukraine and shipping them via Nova Poshta with cash on delivery must determine how to issue receipts under their contracts and the actual payment method. Nova Poshta delivers shipments, while NovaPay provides a payment service. For a distance sale with no advance payment, full payment on receipt through NovaPay, and funds credited directly to the seller’s business bank account, the Supreme Court, in its ruling of 3 June 2026 in case No. 520/27700/25, found no obligation for the seller to use a settlement transaction registrar (RRO). The owner and accountant should compare all circumstances of their sale with those of that case.

Before the first shipment, determine who issues the document for the goods and how the buyer receives it. If the shop processes the sale through an RRO or a software settlement transaction registrar (PRRO), the responsible employee creates a receipt for the full value of the goods, correctly showing the deferred payment. The accountant links the subsequent bank transfer to this sale, records separately the commission withheld from the seller, and checks that the payment has been settled. Shipment of the goods, creation of the receipt, and receipt of the money must be monitored separately.

Documents required for delivery, transfer, and sale

Keep documents for each order that allow the movement of goods and money to be traced separately. The manager prepares the shipment, the responsible employee gives the buyer a document confirming the purchase of the goods and showing the sale date, and the accountant matches the payment to the order. If the seller is lawfully not using an RRO or PRRO, they must still provide a document confirming the purchase, such as a sales receipt or delivery note. A NovaPay transfer receipt does not replace the seller’s document showing what the purchase contained.

Regulation approved by Ministry of Finance Order No. 13 separately defines a fiscal cash receipt for goods and a receipt for accepting funds for subsequent transfer. Therefore, a payment institution’s fiscal document held by the buyer does not, by itself, confirm that the seller has fulfilled an obligation to issue a receipt for the goods, if such an obligation applies.

How to determine whether the seller needs an RRO or PRRO

Start by reviewing the definition of a settlement transaction in Article 2 and the seller’s obligations in Article 3 of Law No. 265/95-VR. The law covers cash payments and payments using payment cards. Crediting sales proceeds to an account after a card payment does not create a general exemption from issuing a fiscal receipt.

At the same time, an RRO or PRRO is not mandatory for every sole proprietor in all circumstances. Paragraph 296.10 of the Tax Code of Ukraine exempts single-tax payers in Group 1 from using them. Before relying on this exemption, the accountant must separately establish whether the entrepreneur’s actual activities meet the conditions for remaining in that group. Simply being registered in Group 1 is not grounds for extending its rules to any kind of online retail.

Article 9 of Law No. 265/95-VR also contains specific exceptions. In particular, paragraph 14 concerns payments for services made exclusively through remote banking systems or money transfer services. This exception cannot be applied to the sale of goods merely because a payment service is used.

How to apply the Supreme Court’s conclusion on cash on delivery

In its ruling of 03.06.2026 in case No. 520/27700/25, the Supreme Court found no obligation for the seller to use an RRO in a specific combination of circumstances: a distance sale of goods, delivery by Nova Poshta, no advance payment, even in part, full payment on receipt through “Post Finance”/NovaPay, and funds credited directly to the seller’s current account. The Court also took into account that actual transactions matched the documentation and that no income had been concealed.

For your own shop, prepare a list of these conditions with your accountant and compare it with your contracts, orders, transfer registers, and bank statements. The Court’s conclusion should not automatically be applied to sales involving an advance payment, direct card payment to the shop, cash received by the seller, or transfers to a personal card. The ruling does not change the wording of the law and does not guarantee the same outcome in different circumstances.

Why a direct transfer by IBAN should be considered separately

A direct bank transfer that the buyer initiates to the business account using an International Bank Account Number (IBAN) follows a different flow of funds from cash on delivery through NovaPay. For this payment method, the shop provides an invoice with its bank details, and the accountant uses the payment documents to confirm that the buyer made a direct bank transfer to the business account. If the seller does not carry out a settlement transaction as defined in Article 2 of Law No. 265/95-VR, the transfer does not need to be processed through an RRO or PRRO. Merely listing an IBAN in the shop’s payment details does not turn payment through a card service into a direct bank transfer.

What to agree with the accountant before accepting orders

The shop owner should approve a clear procedure for the manager, warehouse employee, and accountant. It is practical to describe it separately for full cash on delivery, an advance payment with the balance due later, and full prepayment.

1. Compare the contracts with the actual actions. Determine who delivers the goods, who accepts the money, whether an intermediary settles the payment for the goods on the seller’s behalf, and who issues the relevant document. The service’s name in an advertisement is not enough to make this determination.
2. Check the recipient of the money. The entrepreneur’s details in the payment documents must match the seller named in the order. To rely on the Court’s conclusion concerning full cash on delivery, separately confirm that funds were credited to the business bank account.
3. Determine when and how the document will be provided. Record who creates the receipt, who puts a paper copy in the parcel or sends it electronically, and how the employee checks that this was done.
4. Set a reconciliation procedure. The accountant should receive the order number, TTN, value of the goods, receipt details, amount of payment accepted, commission, and amount credited.
5. Describe what to do in case of refusal or return. Employees should separately record the goods’ return to the warehouse, the payment status, and any required actions involving a fiscal document.

Inform the buyer of the payment and delivery terms before they place the order, and confirm them in writing or by electronic message. This follows from Article 13 of the Law on Consumer Protection. The method, timing, and procedure for payment must also comply with the electronic contract under Article 13 of the Law on Electronic Commerce.

When to request an individual tax consultation

If the contracts or flow of funds could be interpreted in different ways, the entrepreneur can request an individual tax consultation (ITC). Describe the actual sales procedure in the request: whether there is an advance payment, how the buyer pays, the role of each intermediary, the account to which funds are credited, and the documents the buyer receives. Ask specific questions about whether an RRO or PRRO must be used and when the receipt must be issued.

Under Articles 52–53 of the Tax Code of Ukraine, an ITC is individual in nature and may be used exclusively by its addressee. A written or electronic consultation must include a registration number, description of the circumstances, reasoning, and conclusion. Another person’s ITC is not your personal consultation, and following a consultation does not cancel the obligation to pay a tax liability.

How to proceed if the shop issues a cash-on-delivery receipt through an RRO or PRRO

If you choose a procedure that involves issuing a fiscal receipt, arrange to prepare it before handing the parcel to the carrier. This allows the employee to enclose a paper document or send an electronic one in advance. Article 3 of Law No. 265/95-VR requires a document for the full amount of the transaction when the goods are received, while part eleven of Article 8 of the Law on Consumer Protection requires it to be issued or created electronically no later than when the goods are handed over.

1. The manager confirms the items in the order. The receipt must list all goods, their quantities, prices, discounts, and the full purchase amount. A payment institution’s commission withheld from the seller does not reduce the sale price of the goods.
2. The accountant approves the deferred payment settings. The receipt must show the amount the buyer still has to pay. The mode name in the accounting software is checked against the form and means of payment shown on the fiscal document.
3. The responsible employee gives the receipt to the buyer. For an electronic document, use the phone number or email address provided by the buyer. Check that the buyer can access the fiscal document with its number, rather than only an invoice for payment.
4. The accountant links the NovaPay transfer to the recorded sale. A credit that settles payment for this purchase is not recorded as a new sale of the same goods.

Under Sections I–II of Regulation No. 13, check the seller’s and business unit’s details, tax number, product names, quantities, value, applicable taxes, form and means of payment, date, time, and fiscal details. A business unit here means the premises where the seller sells goods and processes payments.

Use product names that make it clear what the buyer purchased. Sole proprietors who are single-tax payers and are not registered value-added tax (VAT) payers may use a simplified name that reflects the product’s consumer characteristics and unambiguously identifies its product group under State Classifier of Products and Services DK 016:2010. This right does not apply to excisable goods; technically complex household goods subject to warranty repair; medicines; medical devices; or jewelry and household items made of precious metals, precious stones, precious stones of organic origin, and semi-precious stones. A general entry such as “замовлення” (“order”) does not adequately describe the contents.

The form and means of payment must match the actual settlement. If the buyer used a card with a payment provider, that alone does not mean there was a card payment through the shop’s terminal. Do not enter invented terminal, card, or authorization details: Regulation No. 13 links completion of the relevant fields to actual use of a terminal connected to or integrated with an RRO or PRRO.

When to recognize income and how to account for the commission

For a sole proprietor who is a single-tax payer, the date of monetary income is determined by the receipt of funds under paragraph 292.6 of the Tax Code of Ukraine. For full cash on delivery through NovaPay with funds credited to an account, use the crediting date. The Supreme Court ruling in case No. 520/27700/25 also cites this approach to the income date. Shipping goods that have not been paid for or issuing a receipt with deferred payment does not mean that money has been received.

The accountant must establish the full payment amount for the goods and separately record the commission withheld from the seller. For a single-tax payer, transfer costs do not reduce sales income. If the buyer separately pays the payment provider’s commission, it does not become shop revenue just because it appears on the same payment receipt.

Illustrative example. A sole proprietor who is a single-tax payer and not a VAT payer sells goods for UAH 2,000. Under the agreement, a UAH 40 commission charged to the seller is withheld from this amount, and UAH 1,960 is credited to the account. Sales income is UAH 2,000; the difference, UAH 2,000 − UAH 1,960 = UAH 40, is an expense for the payment service. These are illustrative amounts, not NovaPay’s rates.

For a sole proprietor on the general taxation system, Article 177 of the Tax Code of Ukraine provides for taxation of net income, the difference between revenue and documented expenses related to the business. The commission must be recorded separately, taking its nature and supporting documents into account. For VAT payers, separate rules govern the exclusion of VAT amounts included in the value of goods from income.

How to reconcile cash on delivery each day

Assign an employee to match shipments with payments. Under the agreement for crediting cash on delivery to an account, a business can receive registers showing the shipment number, payer details, date, amounts accepted and transferred, and commission. This is a paid service; agree on the connection procedure, account to be credited, and current commercial terms in the contract.

For internal control, keep one row for each shipment: order number, TTN, value of the goods, receipt number if applicable, date the parcel was received, payment amount, seller’s commission, credit date and amount, and outstanding balance. If one transfer covers several parcels, allocate it using the register.

After reconciliation, it should be clear which orders have been paid, for which ones a transfer is pending, which parcels are being returned, and why the amount credited differs from the value of the goods. Use the delivery status to track the parcel and financial documents to confirm receipt of funds. Article 44 of the Tax Code of Ukraine requires supporting documents to be retained for tax accounting.

Accounting for Nova Poshta cash on delivery and receipts in Torgsoft

In Torgsoft, the manager creates an invoice with the goods and then creates a delivery note without payment based on that invoice. An accounting center is a shop or warehouse in Torgsoft from which goods are shipped. The “Торгівля з випискою рахунка” (“Trade with invoice issuance”) mode is available in the paid Ультра (Ultra) and Термінал (Terminal) licenses; Старт (Start) does not support invoice issuance.

Review the current license terms before purchasing. A separate paid option, “Інтеграція з Новою поштою” (“Integration with Nova Poshta”), an internet connection, and a valid Nova Poshta application programming interface (API) key are required to create, print, and track TTNs. A specialist configures the sender and their address, while the manager checks the recipient, phone number, delivery location, party responsible for delivery costs, and cash-on-delivery amount. “Контроль оплати” (“Payment Control”) is available under the relevant agreement; automatic selection depends on the service being available to the sender, the cash-on-delivery flag, and the unpaid delivery note amount.

The option is paid for annually: for certain versions, one license per workstation; for a local network, one per network; and for a terminal license, one per server.

To work with fiscal receipts, activate the separate paid “Програмний РРО” (“Software RRO”) option or, for a hardware RRO, “Інтеграція з фіскальним реєстратором” (“Fiscal Registrar Integration”). Each is paid for annually and licensed separately for every device. Prices and purchase terms for all these options are listed on the additional options page. For PRRO, a specialist opens “Налаштування → Параметри → Чек” (“Settings → Parameters → Receipt”), sets the conditions “Пропонувати друк” (“Offer printing”) or “Друк чека завжди” (“Always print receipt”), and for a delivery note receipt, “На суму оплати та боргу” (“For the payment and debt amount”) or “Спитати користувача” (“Ask the user”).

In the payment means settings, “Кредит” (“Credit”) must allow another form of payment and use for debt. Before printing, the employee checks that all goods to be processed through the PRRO are marked as fiscal. When shipping without payment, in the “Формування чека клієнту” (“Create a customer receipt”) form, the employee selects “На суму оплати та боргу” (“For the payment and debt amount”), payment form for debt “Інше” (“Other”), and means “Кредит” (“Credit”).

These values represent the unpaid part of the purchase. The accountant checks the receipt against the delivery note: goods, quantities, full value, debt, and fiscal number. Under the PRRO rules for trade with invoices, this receipt is final: another receipt cannot be created when payment for this delivery note is received later.

After the bank credit, the accountant records the payment and commission separately using the NovaPay register and statement. This is the normal accounting of funds received; the final fiscal receipt does not replace recording the bank payment. Use the sequence below for manual accounting. After completing it, reconcile the settled delivery note amount, expenses, and change in the account balance; the delivery note can then be marked as reconciled. The warehouse employee tracks the quantity and movement of goods in “Стан складу” (“Warehouse Status”).

1. Record the full payment for the goods. On the “Видаткова накладна” (“Delivery Note”) tab, open “Внести оплату за товар” (“Record payment for goods”), select a non-cash payment form, the required settlement account, and the company. Enter the credit date and the full amount paid by the buyer for the goods. In the illustrative example above, this is UAH 2,000. Select “Не враховувати еквайринг” (“Do not account for acquiring”) so the program does not add an extra percentage expense when the commission actually withheld is recorded separately.

2. Record the seller’s withheld commission separately. From the “Оплата → Фінансовий документ” (“Payment → Financial Document”) menu, on the “Розрахунковий рахунок” (“Current Account”) tab, open “Створити платіжне доручення” (“Create Payment Order”). Enter the payer and the same shop account, the recipient of the funds—the payment service provider under the agreement—and its settlement account. Enter the date and amount withheld; in the example, UAH 40. Since you are recording this UAH 40 as a separate expense, check that the “Комісія банку” (“Bank commission”) field does not add another commission to the document.

   Specify a financial analysis item, meaning an expense category, such as “Комісія NovaPay” (“NovaPay commission”) that you created, and a purpose referring to the register. This records the commission already withheld in management accounts; the money does not need to be transferred to the service provider again.

3. Reconcile the result. The illustrative example should show a UAH 2,000 payment against the delivery note, UAH 0 debt, a UAH 40 expense, and a UAH 1,960 increase in the account balance: 2,000 − 40 = 1,960. Do not add a commission paid separately by the buyer at their own expense to the seller’s expenses.
4. Avoid entering the statement twice. If the shop uses the paid “Банківські виписки” (“Bank Statements”) option, after recording the transaction manually, apply “Позначити як передану” (“Mark as transferred”) to the corresponding row. Entering UAH 1,960 again will duplicate the credit. The option requires activation and setup of access to a supported bank: Privat24, monobank, or UKRSIBBANK. It is paid for annually; for certain versions, one license per workstation; for a local network, one per network; and for a terminal license, one per server. Review the current commercial terms before connecting.

What to do if the buyer refuses or returns the goods

The parcel was not collected or paid for

The manager records the refusal and the return shipment number. After the goods are physically returned, the warehouse employee inspects them, checks the quantity, and records the return in the accounting system. The accountant checks whether payment was made and a fiscal receipt issued, and separately records the shop’s delivery costs.

If a receipt with a debt has already been created in Torgsoft for a fully unpaid delivery note, the responsible employee opens the original delivery note, selects “Повернення накладної” (“Return delivery note”), and chooses the goods and quantities actually returned. Next, on the “Повернення” (“Returns”) tab, they select “Надрукувати фіскальний чек” (“Print fiscal receipt”). Torgsoft supports a fiscal return receipt without paying money to the customer; for PRRO, when no payments were made against the delivery note, the return is shown with “Кредит” (“Credit”) as the payment. Since the buyer did not pay, do not use “Виплатити” (“Pay out”) for this refusal.

The accountant retains the original receipt, return receipt, and documents showing the refusal. After a full return, employees check that the goods have been restored to the correct warehouse stock, no debt remains for the canceled purchase, and no cash or bank payment was made to the buyer. Shipping costs are tracked separately. Deleting a payment does not replace processing a return: the previously issued fiscal receipt will not disappear.

The buyer received and paid for the goods, then returned them

The manager receives the request, finds the original order and payment, and determines the grounds for the claim under Articles 8, 9, or 13 of the Law on Consumer Protection. The grounds determine the right to return the goods, the reimbursement amount, the deadlines, and shipping costs.

• The goods are defective. Under Article 8, an ordinary defect discovered during the warranty period gives the buyer the right to request a price reduction, repair, or reimbursement of repair costs. Termination of the contract is possible, in particular, for a material defect caused by the manufacturer or seller, or for counterfeiting, where necessary confirmed by an expert examination. Separate rights to replacement or a refund apply to food products unfit for consumption.
• Non-food goods of proper quality are unsuitable. Under Article 9, the buyer first has the right to exchange them within fourteen days, excluding the day of purchase, unless the seller has announced a longer period. The manager checks that the goods have not been used and that their appearance, consumer properties, seals, labels, and payment document have been preserved. The manager also checks the goods against the list in Appendix No. 3 to Cabinet of Ministers Resolution No. 172. If an equivalent item is unavailable, the buyer may choose to terminate the contract and receive a refund at the purchase price.
• The buyer terminates a distance contract. The right under Article 13 is checked separately from an exchange under Article 9. The manager establishes the applicable period, notification date, and whether statutory exceptions apply, then informs the buyer of the return procedure.

For a claim based on defects, the manager checks the payment document and, for goods covered by a warranty, also checks the technical passport or equivalent document marked with the sale date. For medicines, medical devices, and technically complex household goods, part eleven of Article 8 separately requires the payment document prescribed by legislation on RROs. The seller must accept goods of improper quality. The seller or manufacturer pays for delivery of such bulky goods, or goods weighing more than five kilograms, to the seller and their return to the buyer.

When a contract is terminated due to defects, the accountant takes into account any price increase as of the date of the claim; if the price has decreased, the purchase price applies. If the seller proves that defects arose because the buyer violated the rules for use or storage of the goods, the claims under part one of Article 8 must be rejected. The buyer has the right to take part in a quality inspection in person or through a representative. For non-food goods that have been used and were sold through a retail consignment shop, these claims are satisfied with the seller’s consent if the warranty period has not expired.

How to account for deadlines and shipping in a distance return

For a distance purchase, Article 13 provides a period of fourteen days from confirmation of the information or receipt of the goods or first delivery. If confirmation of the information does not meet statutory requirements, the period is ninety days from receipt of the information or, for physical goods, from receipt of the goods or first delivery. If corrected confirmation is received within that period, the buyer has a further fourteen days to terminate the contract.

Unless the contract provides otherwise, exceptions include goods whose price depends on financial market quotations; goods manufactured or processed to order that cannot be sold to another person or can be sold only at significant financial loss; audio or video cassettes or software media unsealed by the buyer; and delivery of periodicals. A separate exception covers a service or goods supplied electronically before the termination period ends, with the buyer’s consent, if the buyer was informed of this in the confirmation of information.

Under part seven of Article 13, parts five to nine of Article 12 apply to distance contracts. The buyer informs the seller where the goods can be returned; the contract may provide for postal returns. The seller bears the costs associated with returning the goods and must reimburse the buyer’s related expenses. The manager must arrange to receive the goods: after sixty days from receipt, the buyer’s obligation to keep the goods ends, and if the seller has not taken steps to have them returned, ownership passes to the buyer without any obligation to pay.

The buyer must keep the goods in an unchanged condition. Opening the packaging, inspecting, or checking the goods in a way that reduces their value does not, by itself, remove the right to terminate a distance contract; the right also remains if the goods are damaged or spoiled through no fault of the buyer. If the buyer was not given a document or confirmation of the information and notified the seller that the contract was invalid, the seller must refund the money and reimburse return costs within thirty days of receiving the notice.

For failure to meet the deadline for refunding money, part nine of Article 12 provides for a penalty of one percent of the product’s value for each day of delay.

How to record the goods, payout, and return receipt

The warehouse employee accepts and inspects the goods, while the accountant determines the refund amount, method, and timing according to the grounds for terminating the contract. If the contract is terminated under Article 8 or 9, the money is refunded on the date of termination or, if that is not possible, within a period agreed by the parties, no later than seven days. For a settlement transaction involving a refund, Section III of Regulation No. 13 provides for a fiscal return receipt.

In Torgsoft, the employee creates a return against the original delivery note and checks the goods and quantities. For a paid purchase, the accountant uses “Виплатити” on the “Повернення” tab (“Pay out” on the “Returns” tab). If the money is refunded from a bank account, select “Повернути все з розрахункового рахунку” (“Refund all from the current account”) and the required account in the additional parameters.

The accountant retains proof of the actual transfer to the buyer. If a fiscal receipt was issued for the original sale, the responsible employee checks that a fiscal return receipt is available. If one has not yet been created, they select “Надрукувати фіскальний чек” (“Print fiscal receipt”) on the “Повернення” tab and check the goods, amount, payout form, and fiscal number. The accountant then reconciles the actual refund, financial records, and warehouse stock.

For single-tax purposes, also retain the documentary basis for the refund, taking into account subparagraph 5 of paragraph 292.11 of the Tax Code of Ukraine.

What mistakes can lead to a fine

If an RRO or PRRO is required, processing a transaction for less than the full amount, failing to process it through the registrar, or failing to issue the proper document may result in penalties under paragraph 1 of Article 17 of Law No. 265/95-VR: 100% of the sale amount processed in violation for the first violation and 150% for each subsequent violation. Temporarily reduced penalties of 25% and 50% for sole proprietors defined by law were limited to the period from 1 August 2023 to 31 July 2025, but no later than the termination or cancellation of martial law in Ukraine.

Also consider paragraph 14 of Section II of this Law: starting on 1 October 2023, it provides a territorial exemption from liability, subject to specified conditions, for sales in temporarily occupied territories and territories of active or possible hostilities. The exemption depends on the territory category and relevant dates in the official list and does not apply to violations involving the sale of excisable goods. This exemption from liability does not cancel the payment requirements themselves.

Before each shipment, the employee must check the order contents, cash-on-delivery amount, and compliance with the agreed procedure for providing the document. Once the money is credited, the accountant checks the full amount of income, the separate commission, and settlement of payment for the same order.

Legislation on processing cash on delivery

• Law of Ukraine “On the Use of Settlement Transaction Registrars in Trade, Public Catering, and Services,” dated 06.07.1995 No. 265/95-VR: Articles 2, 3, 9, 17; paragraphs 14–15 of Section II.
• Ministry of Finance of Ukraine Order dated 21.01.2016 No. 13, “On Approval of the Regulation on the Form and Content of Settlement Documents/Electronic Settlement Documents…”: Sections I–III and VI of the Regulation; forms of fiscal receipts for goods, payouts, and money transfers.
• Tax Code of Ukraine dated 02.12.2010 No. 2755-VI: Articles 44, 52–53, 177; paragraphs 292.1, 292.6, 292.11, 296.10.
• Law of Ukraine “On Consumer Protection,” dated 12.05.1991 No. 1023-XII: Articles 8, 9, 12–13.
• Resolution of the Cabinet of Ministers of Ukraine dated 19.03.1994 No. 172, “On the Implementation of Certain Provisions of the Law of Ukraine ‘On Consumer Protection’”: Appendix No. 3, list of goods of proper quality that cannot be exchanged or returned.
• Law of Ukraine “On Electronic Commerce,” dated 03.09.2015 No. 675-VIII: Article 13.
• Supreme Court ruling dated 03.06.2026 in case No. 520/27700/25: use of an RRO under the specific procedure for full cash on delivery through “Post Finance”/NovaPay to the seller’s current account.