In what cases will the tax authorities cancel the registration of a cash register?

The tax authority may cancel PRRO registration: when this happens and what an entrepreneur should do

A PRRO does not operate indefinitely “by itself”, but until the date its registration is cancelled. After cancellation, the software RRO is excluded from the PRRO Register, and its fiscal number is closed — this number can no longer be used. Cancellation may be initiated by the entrepreneur, and in certain cases it happens automatically through the STS fiscal server.

The main point for an entrepreneur: before cancellation, it is necessary to close the shift, generate a fiscal reporting receipt or fiscal report, and transmit to the fiscal server all receipts, Z-reports, notifications and documents created in offline mode. After cancellation, sales through this PRRO are not allowed: a new PRRO must be registered, another registered PRRO or RRO must be used, or settlement transactions for which an RRO/PRRO is mandatory must be temporarily suspended.

When an entrepreneur needs an RRO or PRRO at all

RRO or PRRO is used by business entities that carry out settlement transactions in cash or non-cash form using electronic payment instruments, payment checks, tokens, etc. when selling goods or providing services in trade, catering and services. The payment must be made for the full amount of the purchase or service, and the buyer must receive a settlement document of the established form and content.

A PRRO cannot be used for wholesale or retail fuel trade. For such transactions, the law directly prohibits the use of a software RRO.

Not all transactions require RRO/PRRO. For example, RRO/PRRO and settlement books are not used in cases directly defined by Article 9 of the Law on RRO: in particular, for certain banking transactions, certain ticket sales, some types of market trade, sales of certain goods from tank trucks, and also if no cash settlements are carried out at the place where goods are received or services are provided. A separate rule applies to single tax payers: RRO/PRRO is not used by first-group single tax payers.

What cancellation of PRRO registration means

Cancellation of PRRO registration — is not a fine and not an audit. It is a technical and legal action after which the PRRO can no longer be used for fiscalization of sales. The fiscal number of such PRRO is closed, and the PRRO itself is excluded from the Register.

After cancellation:

• the fiscal number cannot be reused;

• new receipts cannot be created through this PRRO;

• buyers cannot be issued receipts from an already cancelled PRRO;

• to continue work, another registered PRRO/RRO must be used or a new one must be registered;

• if the shift was not closed, the fiscal server allows only the generation of a Z-report and closing of the shift.

How an entrepreneur can cancel a PRRO independently

An entrepreneur or legal entity may independently submit an application to cancel PRRO registration. For this, the Application for registration of a software registrar of settlement transactions in form No. 1-PRRO is used with the mark “Cancellation of registration”. The current form identifier is J/F 1316605.

Before submitting the application, it is necessary to:

1. Check that there is no open shift on the PRRO.

2. Generate a fiscal reporting receipt or fiscal report for the shift.

3. Transmit all electronic settlement documents to the fiscal server.

4. Transmit all documents created in offline mode with offline fiscal numbers.

5. Transmit electronic fiscal reporting receipts, electronic fiscal reports and notifications provided for by Procedure No. 317.

6. Submit form No. 1-PRRO through the Electronic Cabinet, API or other telecommunication means.

7. Check messages in the Electronic Cabinet and the PRRO status in the Register.

If an entrepreneur cancelled a PRRO but forgot to close the shift, the STS explains that the software must allow entry to the cash register of the cancelled PRRO only to generate a Z-report and close the shift. Other operations on such PRRO cannot be performed.

Cancellation due to malfunction, device theft or key compromise

If the PRRO is faulty, the device has been stolen or lost, or there is a risk of compromise of the private key, a Notification of detected malfunctions of the software registrar of settlement transactions in form No. 2-PRRO is submitted. The current form identifier is J/F 1316701.

The notification in form No. 2-PRRO is submitted during the day when the malfunction was detected. It is sent to the controlling authority, the PRRO developer and/or the service center, if any. During the period when the PRRO is out of order, settlement transactions through it are not carried out until the malfunction is eliminated or a backup RRO is connected.

If the notification indicates a malfunction, a mark is entered in the Register that the PRRO is faulty. After the malfunction is eliminated, an application marked “Restoration of operation” is submitted to resume work. If such an application is not received within one month, a record on cancellation of PRRO registration is entered in the Register.

If the device has been stolen or the key has been compromised, it is safer to immediately stop working through such PRRO, submit form No. 2-PRRO with the appropriate mark and register a new PRRO. The old fiscal number is not used after cancellation.

When the tax authority cancels a PRRO automatically

Automatic cancellation occurs through the fiscal server without a separate cancellation application from the entrepreneur. After that, the business entity receives a notification through the Electronic Cabinet indicating the grounds.

In practice, the risk of automatic cancellation most often arises when the status of a business unit changes. If an entrepreneur submitted form No. 20-OPP and indicated a store, warehouse, kiosk, salon or another object as closed or not in operation, the system may automatically cancel the PRRO registered for this object. The STS directly explained: when an object is closed through form No. 20-OPP, PRRO registration is cancelled through the fiscal server.

When PRRO cancellation is not needed

Not every change in business means that a PRRO must be cancelled. In many cases, re-registration or changes to PRRO data are sufficient.

PRRO re-registration is carried out if the following changes:

• name or full name of the business entity without termination of the individual entrepreneur or legal entity;

• tax number;

• name of the business unit;

• address of the business unit where the PRRO is used.

For re-registration, form No. 1-PRRO is submitted with the mark “Re-registration”. Before that, the last shift must be closed and the last fiscal reporting receipt must be sent.

If data changes that do not require re-registration, for example the PRRO name, an application is submitted to amend PRRO data. Cancellation of registration is not required for this.

What to check before cancelling a PRRO

Before submitting an application or notification, it is worth going through a short checklist:

Offline mode and PRRO cancellation

A PRRO may work offline only within established limits: no more than 36 hours in a row and no more than 168 hours during a calendar month. In this mode, electronic settlement documents are assigned fiscal numbers from a range generated by the fiscal server.

After connection is restored, the PRRO must generate a notification on completion of offline mode and transmit the data package to the fiscal server within one hour. Before cancelling the PRRO, it is necessary to make sure that such documents have been transmitted.

If offline documents have not been transmitted, the entrepreneur risks a problem not because of cancellation itself, but because of improper fulfillment of the obligation to transmit settlement documents and reports.

PRRO, staff and electronic signatures

A PRRO may be used only on a device that belongs to the business entity by ownership, possession or use rights. Settlement transactions through a PRRO may be carried out only by those persons whose electronic signature or seal certificates are entered in the Register for this PRRO.

To enter certificates, a notification is used regarding qualified or advanced public key certificates used in the PRRO. The STS indicates form J/F 1391802 for this.

If a cashier resigns, the key is compromised or the responsible person changes, certificate data must be updated in a timely manner. If the key is compromised, work through such PRRO should be stopped and actions should be taken through form No. 2-PRRO.

Excisable goods, labeling and PRRO

For excisable goods, the PRRO must work with a programming mode indicating the goods subcategory code according to UKTZED, the name, price and quantity of goods. For retail trade in alcoholic beverages, the digital value of the excise tax stamp barcode is additionally indicated — series and number.

Violation of this rule is a separate financial risk. For conducting settlement transactions through RRO/PRRO without programming the name of each excisable product with indication of the UKTZED code, price and quantity accounting, a financial sanction of 300 non-taxable minimum incomes of citizens is provided.

Cancellation of a PRRO does not cancel licenses for trade in excisable goods, but the sale of alcohol, tobacco, liquids for electronic cigarettes or other excisable goods without proper fiscalization and correct receipt details may lead to separate sanctions.

Delivery, online stores and PRRO

If a product or service is ordered or paid for via the internet, but a settlement transaction takes place, the buyer must be provided with a settlement document of the established form and content. The receipt may be paper or electronic: in particular, via a QR code on the device display, sent to the buyer’s phone number or email.

If the PRRO has been cancelled, an online store cannot fiscalize new payments through it. Before continuing sales, another PRRO must be registered or another lawful method of conducting settlements must be used.

What fines are possible if sales continue after PRRO cancellation

If, after cancellation of the PRRO, the entrepreneur continues to carry out settlement transactions through an unregistered or cancelled PRRO, this may be considered failure to conduct a settlement transaction through an RRO/PRRO with fiscal mode of operation or failure to provide a proper settlement document.

For such violations, Article 17 of the Law on RRO provides for financial sanctions:

Financial sanctions under the Law on RRO are paid to the state budget within 10 calendar days from the day they are agreed. Separately, officials and employees who violated the settlement procedure may bear administrative liability under the Code of Ukraine on Administrative Offenses.

What to do if a PRRO was cancelled automatically by mistake

If an entrepreneur received a notification about automatic cancellation of a PRRO, it is necessary to:

1. Check the grounds indicated in the Electronic Cabinet.

2. Check the business unit status in form No. 20-OPP.

3. Check whether the object was mistakenly submitted as closed or not in operation.

4. Check the relevance of data in the Unified State Register.

5. If the error is related to the taxation object — submit an amended form No. 20-OPP.

6. If necessary, register a new PRRO for the correct business unit.

The STS recommends, after submitting form No. 20-OPP, checking whether the data on taxation objects correspond to the data on the business unit, and in case of discrepancies — resubmitting form No. 20-OPP and/or re-registering the PRRO. In case of automatic PRRO cancellation, the PRRO may be registered again for a new business unit.

Practical example

An entrepreneur closes a store and submits form No. 20-OPP, in which the business unit is indicated as closed or not used. If a PRRO was registered for this store, the system automatically cancels its registration through the fiscal server. This is confirmed by the clarification of the Main Department of the STS in Dnipropetrovsk region dated July 3, 2025, regarding closure of a business unit and consequences for RRO/PRRO.

What users of the Torgsoft software RRO should consider

A software RRO within an accounting system — is a tool for creating and transmitting fiscal documents. Responsibility for the correctness of data about the individual entrepreneur or legal entity, business unit, tax status, electronic signatures, product names, UKTZED codes, prices, quantity, excise details and timely closing of shifts lies with the business entity carrying out settlement transactions.

Before cancelling or re-registering a PRRO, it is necessary to check not only the software settings, but also the data in the STS Electronic Cabinet: form No. 20-OPP, the business unit status, validity of keys, presence of an open shift and transmission of all documents to the fiscal server. This reduces the risk of cash register operation blocking, mistaken automatic PRRO cancellation and claims during an audit.

Official sources

1. Law of Ukraine “On the use of registrars of settlement transactions in trade, catering and services” No. 265/95-VR: Articles 2, 3, 7, 8, 9, 10, 12-1, 17, 20, 25, 26.
   Link: https://zakon.rada.gov.ua/go/265/95-%D0%B2%D1%80

2. Order of the Ministry of Finance of Ukraine dated 23.06.2020 No. 317 “On amendments to the order of the Ministry of Finance of Ukraine dated June 14, 2016 No. 547”: Procedure for registration, maintaining the register and use of software registrars of settlement transactions, sections II, III, IV, V; forms No. 1-PRRO, No. 2-PRRO, No. 4-PRRO.
   Link: https://zakon.rada.gov.ua/go/z0635-20

3. Tax Code of Ukraine No. 2755-VI: Articles 63, 67, 296.10.
   Link: https://zakon.rada.gov.ua/go/2755-17

4. Order of the Ministry of Finance of Ukraine dated 09.12.2011 No. 1588 “On approval of the Procedure for accounting of taxpayers and fee payers”: section VIII, form No. 20-OPP, clauses 8.1–8.5.
   Link: https://zakon.rada.gov.ua/go/z1562-11

5. Code of Ukraine on Administrative Offenses No. 8073-X: Article 155-1, Article 26 of the Law on RRO regarding administrative liability.
   Link: https://zakon.rada.gov.ua/go/8073-10

6. Official STS page “PRRO Forms”: current identifiers of forms J/F 1316605, J/F 1316701, J/F 1316901, J/F 1391802.
   Link: https://tax.gov.ua/baneryi/programni-rro/formi-prro/formi-prro/

7. STS clarification in ZIR regarding shift closing and generation of a Z-report on a cancelled PRRO.
   Link: https://zir.tax.gov.ua/main/bz/view/?id=40685&src=ques

8. STS clarification regarding automatic PRRO cancellation when closing a business unit through form No. 20-OPP.
   Link: https://dp.tax.gov.ua/media-ark/local-news/911882.html