Primary documents in trade: documenting sales, payments, delivery, and returns during an audit

To reduce risks during a tax or on-site audit, every business transaction should have a consistent documentary chain: an order or contract, a document confirming the transfer of goods or provision of services, a payment document, a fiscal receipt — when the use of an ECR/pECR is mandatory, and a transport document for transportation. The data in all documents should match in terms of the counterparty, date, goods or services, quantity, price, amount, VAT, payment method, warehouse, recipient, and return.

An invoice for payment alone generally does not confirm shipment, a bank or payment terminal document does not replace a fiscal receipt, a goods transport waybill does not confirm payment, and an ordinary sales receipt does not replace an ECR/pECR document. Automatic generation of related documents from a single transaction reduces the risk of discrepancies, but the legal validity of documents depends on the actual completion of the transaction, the presence of mandatory details, signatures or electronic signatures, correct fiscalization, and proper storage.

Which documents are required for the main transactions

Primary documents serve as the basis for accounting and tax records. Tax figures cannot be formed based on data that is not supported by documents required by law.

Mandatory details of a primary document

A primary document may be in paper or electronic form. It must contain:

• the name of the document;

• the date of preparation;

• the name of the enterprise or person on whose behalf the document was prepared;

• the content and scope of the business transaction;

• the unit of measurement of the transaction;

• the positions and surnames of the persons responsible for the transaction and the correctness of its documentation;

• a personal signature or other data that makes it possible to identify the person who participated in the transaction.

If necessary, the document may also include a number, the basis for the transaction, power of attorney details, a seal, warehouse, contract, order, delivery address, and other details. The use of a seal is not a universal condition for the validity of a primary document unless otherwise established by special rules or a contract.

Primary documents and accounting registers are prepared in Ukrainian. Documents in a foreign language that serve as the basis for accounting entries must have a properly arranged authentic translation into Ukrainian.

Minor deficiencies do not always deprive a document of legal validity. A document may be accepted for accounting if it makes it possible to identify the parties, date, content, scope, and actual completion of the transaction. This rule does not protect documents prepared without an actual transaction, with unidentified goods, or where it is impossible to establish the participants or responsible persons.

What each document confirms

Invoice for payment

An invoice informs the buyer of the details, list of goods or services, price, and amount payable. It is usually issued before shipment or provision of a service, so by itself it does not prove that the goods were transferred, the work was completed, or the money was received.

An invoice may also serve as a primary document only when it records a transaction that has already taken place, contains all mandatory details, and makes it possible to establish its content, scope, and responsible persons. To reduce risks, the sale of goods should be confirmed by a sales invoice, while services or work should be confirmed by an acceptance certificate or another appropriate primary document.

Sales invoice

A sales invoice confirms the transfer of goods from the seller to the buyer. It should specify the parties, date, list of goods, units of measurement, quantity, price, amount, and persons responsible for release and acceptance.

If the buyer receives the goods through an employee, representative, or carrier, it is necessary to determine the basis on which that person accepts the goods. This may be a contract, power of attorney, transportation request, order details, or another document that makes it possible to link the recipient to the buyer.

Certificate of completed work or services rendered

A certificate confirms the fact, content, scope, and period of work performed or services rendered. There is no general rule requiring a document specifically named an «certificate» for all services: a transaction may be confirmed by another primary document if it meets the requirements of Article 9 of the Law on Accounting.

For services, work, and lease transactions, a document signed only by the contractor, lessor, or another party that provided the service, performed the work, or transferred property for use is permitted. This procedure may be applied only if all of the following conditions are met:

• the document contains the date or period when the services were provided, work was performed, or the lease took place;

• the written contract expressly provides for unilateral documentation;

• the transaction is recorded in the accounting records in the period when it was actually completed.

The unilateral procedure does not apply to transactions involving public funds, leases of state or municipal property, construction contracts, design and survey work, as well as donation, charitable, or humanitarian aid agreements.

Sales receipt

A sales receipt may confirm the list of goods transferred to the buyer. However, a non-fiscal receipt printed by accounting software does not automatically constitute a fiscal settlement document.

When a transaction must be processed through an ECR or pECR, the buyer must be provided with a settlement document of the established form and content generated by a registered ECR/pECR. An invoice, sales receipt, bank receipt, or payment terminal slip does not eliminate the obligation to issue a fiscal receipt.

Payment document

Depending on the payment method, payment may be confirmed by:

• a bank statement;

• a payment instruction;

• a bank receipt;

• a cash receipt or cash disbursement order in cases provided for by law;

• a fiscal receipt;

• a payment terminal document;

• a postal money transfer operator’s document;

• a financial document confirming the crediting or refund of funds.

The payment document should be linked to a specific invoice, order, delivery note, or contract. It is advisable to indicate the number and date of the document for which payment is made in the payment purpose.

Tax invoice

A tax invoice is a special tax document of a VAT payer. It does not replace a sales invoice, acceptance certificate, transport document, or fiscal receipt and does not by itself prove the actual transfer of goods or provision of services.

If goods are returned, a prepayment is refunded, or the amount of compensation changes, the VAT payer prepares an adjustment calculation to the tax invoice and ensures its registration in the Unified Register of Tax Invoices in accordance with Article 192 of the Tax Code.

ECR and pECR: when a fiscal receipt is required

Business entities conducting settlement transactions in cash, by payment cards, electronic payment instruments, or other methods provided by law must process the transaction for the full amount through a registered ECR/pECR and provide the buyer with a paper or electronic fiscal receipt. This rule also applies to online sales and returns of goods.

A fiscal receipt may be:

• printed on paper;

• sent to the buyer’s phone number or email address;

• provided via a QR code on the display of a device with a pECR;

• provided in another way that allows the buyer to receive and identify the electronic settlement document.

The form and content of the receipt must comply with the Regulation approved by Order No. 13 of the Ministry of Finance. The absence of mandatory details may mean that the generated document does not meet the requirements for a settlement document.

Payment to IBAN, by card, and via a payment link

According to the explanation of the State Tax Service, when the seller provides the buyer with full current account details in IBAN format and the buyer makes a regular transfer to that account without using card acquiring, such payment may not be considered a settlement transaction, so an ECR/pECR may not be required.

Payment by payment card, internet acquiring, payment link, or POS terminal is a settlement transaction and, as a general rule, requires a fiscal receipt. When payment is made in several installments, a separate receipt is generated for each settlement transaction.

The payment method should be determined not by the wording visible to the buyer, but by the actual movement of funds and payment technology. The designation «payment by bank details» does not exempt the seller from using an ECR/pECR if the buyer actually enters card details on the acquiring page.

Sale with delivery

When full prepayment is made to the seller’s current account using IBAN details, a fiscal receipt may not be issued, but a document for the goods — for example, an invoice or a properly issued sales receipt — should be included with the shipment.

When payment is made in advance by card, the seller must generate a fiscal receipt and include it with the shipment or provide it to the buyer electronically.

For cash on delivery, the obligation to use an ECR/pECR depends on the contract with the carrier and the procedure for accepting and transferring funds. If the carrier accepts payment from the buyer as a financial intermediary and issues its own fiscal receipt, the seller includes documents for the goods with the shipment. If the funds are transferred to the seller in another manner, it is necessary to determine separately who conducts the settlement transaction and when. A seller’s courier who accepts cash or card payment at the delivery location must provide a fiscal receipt for the full amount.

Practical example. An online store accepts payment in two ways. For a buyer who transfers funds directly to the current account using IBAN details, the store ships the goods with a sales invoice. For a buyer who pays the same amount by card through a payment page, the store additionally generates an ECR/pECR fiscal receipt. The fact that both payments are credited to the same bank account does not make the payment methods identical for the purposes of ECR use. This approach is described in the official explanation of the State Tax Service regarding online trade and delivery.

Inventory accounting and documents confirming the origin of goods

An enterprise or Sole Proprietorship subject to paragraph 12 of Article 3 of the Law on ECR must maintain inventory records and sell only goods reflected in such records. At the beginning of an audit, paper or electronic documents confirming the accounting and origin of goods located at the point of sale must be provided.

Documents confirming origin may include:

• a supplier’s purchase or sales invoice;

• a TTN or another transport document;

• a customs declaration;

• a purchase certificate;

• a fiscal or sales receipt;

• an internal transfer document;

• an inventory document;

• another document that identifies the supplier, recipient, date, goods, quantity, and value.

For Sole Proprietorships subject to the special inventory accounting form, records and primary documents are maintained in accordance with Procedure No. 496. Documents may be stored in paper or electronic form but must be available during an audit.

The requirements of paragraph 12 of Article 3 of the Law on ECR do not apply to Sole Proprietorships — single tax payers that are not registered as VAT payers, except for sellers of:

• technically complex household goods subject to warranty repair;

• medicines and medical devices;

• jewelry and household products made of precious metals and gemstones.

This exception applies specifically to the special inventory accounting requirement of the Law on ECR. It does not permit concealment of income, sale of goods of unknown or illegal origin, or violation of special legislation.

For excisable, imported, food, medical, technically complex, and other regulated goods, primary documents do not replace licenses, excise stamps, certificates, declarations of conformity, warranty documents, veterinary, sanitary, customs, or other documents required for a specific product category.

Electronic primary documents

An electronic document has the same legal nature as a paper document if it contains the mandatory details and a proper electronic signature or another means of identifying the author provided by law. The original electronic document is an electronic copy containing the mandatory details, including the author’s electronic signature or a signature legally equivalent to a handwritten signature.

Primary documents automatically generated by an information system may be used in accounting provided that an electronic signature or electronic seal is applied in accordance with legislation on electronic document management and trust services.

A scan or photograph of a paper document without an electronic signature does not become an original electronic document. It is an electronic copy of the paper original, so the paper copy itself must be retained unless it has been properly replaced by an electronic document.

An electronic archive system should ensure:

• document integrity;

• protection against undetectable editing;

• the ability to identify the author and signatory;

• preservation of the signature and certificate verification data;

• document search by date, counterparty, number, and transaction;

• reproduction of the document in a readable form;

• production of a paper copy at the request of the controlling authority.

TTN and delivery documents

A goods transport waybill is the main document for the transportation of goods by road. It may be in paper or electronic form and must contain mandatory information about the consignor, carrier, consignee, vehicle, driver, loading and unloading points, cargo, quantity, and other data established by transport legislation.

Under the current Rules for the Carriage of Goods by Road:

• a TTN is issued regardless of the terms of payment for transportation;

• the consignor prepares a paper TTN in three copies;

• an electronic TTN is signed by the responsible persons of the consignor, the carrier or driver, and the consignee;

• documents required for the specific cargo are attached to the TTN;

• specific categories of cargo are subject to special requirements regarding temperature, packaging, labeling, safety, and accompanying documents.

A TTN confirms transportation but does not automatically confirm payment, fiscalization, or all terms of the sale. For proper documentation of a delivery, it should be linked to the contract, order, and sales invoice.

A document issued by a postal or express carrier, which is also commonly referred to as a TTN, confirms that a shipment has been accepted by a specific operator. The entrepreneur should verify whether its details are sufficient for the relevant transaction and whether a sales invoice, a statutory TTN, documents for the goods, or a fiscal receipt are additionally required.

Documenting returns of goods and funds

A return should be linked to the original sale. The documents should indicate the number and date of the original receipt, invoice, or order, the buyer, goods, quantity, price, amount, reason for the return, and refund method.

A return usually requires:

1. an application, claim, or another document from the buyer — where required by the nature of the return;

2. a return invoice or return certificate;

3. a refund fiscal receipt if the original settlement was processed through an ECR/pECR;

4. a bank or cash document confirming the refund;

5. an adjustment calculation — if the seller is a VAT payer and grounds for adjustment arise.

Funds for a transaction paid by card through an ECR/pECR are generally refunded in a form corresponding to the original payment method, with proper documentation of the settlement transaction.

A consumer has the right to exchange non-food goods of proper quality within fourteen days, excluding the day of purchase, unless the seller has announced a longer period and the statutory requirements regarding the condition of the goods, their use, and proof of purchase are met. For goods included in the list approved by the Cabinet of Ministers, the right to exchange or return goods of proper quality is restricted. Law No. 1023-XII remains in force; the new Law No. 3153-IX has not yet entered into force.

The return of goods of improper quality is documented taking into account the consumer’s specific rights, warranty periods, the nature of the defect, and the requirements of Article 8 of the Law on Consumer Protection.

Document retention and preparation for an audit

The retention period depends on the type of document, taxpayer status, and tax transaction:

The retention period for tax documents is calculated from the date of submission of the reporting for which they were used, or, if the reporting was not submitted, from the filing deadline. For documents related to other legislation supervised by the State Tax Service, the period is calculated from the date of the transaction, and for a permit document — from the date its validity expires. These periods may be extended in cases where the limitation period is suspended, an audit is conducted, or an administrative or judicial appeal is pending.

For a Sole Proprietorship, the specific retention period should be determined according to the document category. In particular, the 1825-day period applies to Sole Proprietorship documents concerning payments to non-residents specified in paragraph 141.4 of the Tax Code, while a 1095-day period may apply to other documents. Documents should not be destroyed if they relate to an unfinished audit, dispute, appeal, criminal proceeding, or a period for which the limitation period has been suspended.

For each transaction, it is advisable to keep a single electronic set containing:

• a contract or order;

• an invoice;

• a document confirming transfer of goods or acceptance of services;

• a TTN or carrier document;

• a fiscal receipt;

• a bank or cash document;

• a tax invoice and adjustment calculation;

• correspondence regarding approval, delivery, a claim, or return;

• documents confirming the origin, quality, and conformity of the goods.

Main penalty risks

Failure to process a settlement transaction through an ECR/pECR, processing it for less than the full amount, or failure to provide a proper settlement document results in a financial penalty:

• 100% of the transaction amount — for the first violation;

• 150% of the transaction amount — for each subsequent violation.

For the sale of unrecorded goods or failure during an audit to provide documents confirming that goods at the point of sale are accounted for, the penalty equals the value of such goods at retail prices, but not less than ten non-taxable minimum individual incomes. The statutory exception for certain Sole Proprietorships paying the single tax does not apply to sellers of technically complex household appliances, medicines, medical devices, and jewelry.

Failure to retain primary documents or failure to provide them to the controlling authority in cases provided by law entails a fine of UAH 1,020, and a repeated violation within a year — UAH 2,040. For certain Sole Proprietorships — single tax payers that are not VAT payers, a limited exemption is provided for failure to retain documents confirming specifically the expenses for purchasing goods or services. It does not cancel the obligation to retain documents on income, settlement transactions, special categories of goods, and other documents required by law.

The existence of a properly completed document does not protect a transaction that did not actually take place. During an audit, not only the form of the documents is assessed, but also the actual movement of goods, provision of services, payment, the parties’ ability to perform the contract, and the consistency of all documents.

How Torgsoft generates invoices, sales invoices, certificates, receipts, returns, payments, and TTNs from sales data

Torgsoft provides a trade with invoice issuance mode in which the invoice, sales invoice, payment, and return are linked. Based on sales data, you can generate and print an invoice, sales invoice, sales receipt, certificate of completed work for services or for goods and services, TTN, and return documents. Templates corresponding to the document type are used for sales invoices, while payment information is linked to the invoice and sales invoice.

This makes it possible to use the same customer, goods, quantity, price, amount, delivery terms, and payment data in related documents instead of transferring them manually between different files. This approach reduces the risk that the invoice contains one amount, the sales invoice contains a different quantity, while the payment remains unlinked to a specific shipment.

For settlement transactions, Torgsoft supports work with fiscal registrars and pECR, including generation of sales and return receipts. Certain features require an appropriate license, connection, or activation of an additional function. In Hybrid mode, the software supports sales, returns, printing of regular and fiscal receipts, and operation with a pECR when the required option is available.

Integrations with postal operators make it possible to create shipment waybills, print labels, combine waybills into registers, and track delivery status without re-entering the main data. The Torgsoft help section describes document generation and shipment tracking for Nova Poshta and Ukrposhta.

Before using templates, you should check the entrepreneur’s details, names of goods and services, units of measurement, VAT rates, fiscalization attributes, payment methods, warehouses, numbering, and signatures. The software helps generate and link documents but does not replace verification of the contract, the actual substance of the transaction, electronic signatures, licenses, certificates, and special requirements for specific goods.

Checklist before an audit

1. For each sale, the path from the order to payment and shipment can be traced.

2. Names, quantity, price, amount, and VAT rate match in the related documents.

3. Invoices are not used as the sole confirmation of shipment or provision of services.

4. Fiscal receipts have been generated for card, cash, and other settlement transactions.

5. Bank transfers to IBAN are separated from card payments and acquiring.

6. Goods at the point of sale are reflected in the records, and documents confirming their origin are available.

7. The return is linked to the original sale and confirmed by an invoice, receipt, and refund document.

8. Tax invoices and adjustment calculations have been prepared for VAT payers.

9. Electronic originals have proper electronic signatures, and scans do not replace paper originals.

10. Documents are retained for at least the period established for the relevant category.

11. Accounting software templates contain the entrepreneur’s current details and correspond to the actual substance of the transactions.

12. Documents can be quickly found by date, counterparty, invoice number, sales invoice number, receipt number, or shipment number.

Official sources

1. Law of Ukraine «On Accounting and Financial Reporting in Ukraine» dated 16.07.1999 No. 996-XIV — Articles 1, 8, 9: primary documents, mandatory details, electronic form, responsibility for documentation.
   https://zakon.rada.gov.ua/go/996-14

2. Law of Ukraine dated 24.02.2026 No. 4791-IX — amendments to Article 9 of Law No. 996-XIV regarding documentation of services, work, and lease transactions with a document containing the details of the performing party.
   https://zakon.rada.gov.ua/go/4791-20

3. Regulation on Documentary Support of Accounting Records, approved by Order No. 88 of the Ministry of Finance of Ukraine dated 24.05.1995 — Section 2: primary documents, language, details, signing, and electronic documents.
   https://zakon.rada.gov.ua/go/z0168-95

4. Tax Code of Ukraine dated 02.12.2010 No. 2755-VI — Articles 44, 121, 192, 201: documentary confirmation of tax accounting, retention periods, penalties, tax invoices, and adjustment calculations.
   https://zakon.rada.gov.ua/go/2755-17

5. Law of Ukraine «On the Use of Registrars of Settlement Transactions in Trade, Public Catering and Services» dated 06.07.1995 No. 265/95-VR — Articles 2, 3, 9, 10, 17, 20: settlement transactions, fiscal receipts, inventory accounting, and financial penalties.
   https://zakon.rada.gov.ua/go/265/95-%D0%B2%D1%80

6. Regulation on the Form and Content of Settlement Documents, approved by Order No. 13 of the Ministry of Finance of Ukraine dated 21.01.2016 — Sections II–III: mandatory details of fiscal cash receipts and refund receipts.
   https://zakon.rada.gov.ua/go/z0220-16

7. Procedure for Maintaining Inventory Records by Sole Proprietorships, approved by Order No. 496 of the Ministry of Finance of Ukraine dated 03.09.2021 — inventory accounting form and documents confirming the origin of goods.
   https://zakon.rada.gov.ua/go/z1411-21

8. Law of Ukraine «On Electronic Documents and Electronic Document Management» dated 22.05.2003 No. 851-IV — Articles 5–8, 13: details, original document, legal validity, and storage of electronic documents.
   https://zakon.rada.gov.ua/go/851-15

9. Law of Ukraine «On Electronic Identification and Electronic Trust Services» dated 05.10.2017 No. 2155-VIII — rules for the use of electronic signatures and seals.
   https://zakon.rada.gov.ua/go/2155-19

10. Rules for the Carriage of Goods by Road in Ukraine, approved by Order No. 363 of the Ministry of Transport of Ukraine dated 14.10.1997 — Sections 10–11 and Appendix 7: preparation of paper and electronic TTNs.
    https://zakon.rada.gov.ua/go/z0128-98

11. Law of Ukraine «On Consumer Protection» dated 12.05.1991 No. 1023-XII — Articles 8, 9, 10: rights in case of defective goods, exchange of goods of proper quality, requirements for work and services.
    https://zakon.rada.gov.ua/go/1023-12

12. Resolution No. 172 of the Cabinet of Ministers of Ukraine dated 19.03.1994 — the current list of goods of proper quality that are not subject to exchange or return.
    https://zakon.rada.gov.ua/go/172-94-%D0%BF

13. Procedure for Completing a Tax Invoice, approved by Order No. 1307 of the Ministry of Finance of Ukraine dated 31.12.2015 — preparation of tax invoices and adjustment calculations.
    https://zakon.rada.gov.ua/go/z0137-16