Software-based electronic cash registers can be used in Ukraine without a connection to the State Tax Service (STS) fiscal server. Offline mode for PECRs has not been abolished, and Article 5 of the Law on ECRs explicitly provides for its use. PECR users do not need to switch to a hardware cash register, a settlement book, or paper receipts simply because their internet connection is lost. The main condition for lawful offline operation is that the PECR must be registered with offline capability enabled and have unused fiscal numbers from a range previously generated by the STS fiscal server.
As a general rule, continuous offline operation is limited to 36 hours, while the use of reserved fiscal numbers is limited to 168 hours per calendar month. However, during martial law, a state of emergency, or force majeure circumstances, paragraph 13 of the Final Provisions of Law No. 265 allows these limits to be exceeded. Martial law was extended for 90 days starting August 2, 2026, so this special exception has practical significance. Even with this exception, offline operation without a range of fiscal numbers obtained from the STS is prohibited.
Has offline operation of PECRs been prohibited?
No. The current Law of Ukraine No. 265/95-VR retains offline mode for PECRs. According to the Verkhovna Rada database, the Law remains in force in its version dated December 30, 2024, and Article 5 continues to regulate the operation of software cash registers when communication with the fiscal server is lost.
Discussions about changing the PECR architecture have indeed taken place at the Ministry of Finance. In 2024, the Ministry established an interdepartmental working group on the use of PECRs. Its officially stated purpose is to develop proposals for improving the system, its architecture, information security, and control mechanisms. The Ministry of Finance's current webpage lists eight meetings of this group, the latest published meeting being September 5, 2025. The working group is an advisory body, so its proposals do not, by themselves, change the rules for businesses. Until the relevant changes are adopted as regulations and enter into force, the current Law No. 265 and Ministry of Finance regulations continue to apply.
Therefore, business owners should rely on the current version of the Law on ECRs and official STS rules rather than announcements about possible future changes.
When is a PECR allowed to switch to offline mode?
Offline mode is intended specifically for situations where communication between the PECR and the STS fiscal server is unavailable. It is not an alternative operating mode that a cashier can choose arbitrarily while a normal connection is available. Procedure No. 317 requires the PECR to return automatically to online mode as soon as communication is restored. Before generating each offline receipt, the software must check whether the connection to the server has been restored.
Operating without the server requires a reserve of fiscal numbers. The fiscal server generates a separate range of numbers for each PECR, which can be assigned to documents during an offline session. The first batch of these numbers is generated by the server, including in response to a PECR request or when a shift is opened. After used receipts are transmitted, the server replenishes the range with new numbers.
A business owner may register a PECR without enabling offline mode. In this case, a range of reserved fiscal numbers is not required, but if communication is lost, transactions cannot be processed through that PECR until the connection is restored.
36 and 168 hours: how the general limits and martial law exception work
| Situation | Rule |
|---|---|
| Standard regulatory conditions | One continuous offline session — no more than 36 hours |
| General monthly limit | Use of reserved fiscal numbers — no more than 168 hours per calendar month |
| Martial law, a state of emergency, or force majeure | The law allows these time limits to be exceeded |
| No unused numbers remaining in the STS-allocated range | Offline transactions are prohibited, even during martial law |
| Connection to the server is restored | The PECR must switch from offline to online mode |
These limits of 36 and 168 hours remain the general rules under Article 5 of Law No. 265 and Procedure No. 317. A separate provision, paragraph 13 of the Final Provisions of Law No. 265, establishes a special rule: during martial law, a state of emergency, or force majeure circumstances, offline transactions and the use of reserved fiscal numbers may continue beyond these time limits. The STS confirms this in its current official explanations.
This exception does not remove the main technical requirement: every offline receipt must be assigned a fiscal number from a range previously generated by the fiscal server. If no unused numbers remain, fiscal sales cannot continue in offline mode.
How is a fiscal receipt generated without internet access?
During an offline session, a PECR creates an electronic payment document for the full transaction amount, just as it does online. The difference is that the document's fiscal number is not assigned by the server at the time of sale but is taken from the range reserved for that particular PECR. The receipt must include an indication that the transaction was processed offline.
The customer can verify such a receipt in the STS database after offline mode ends and the relevant documents have been transmitted to the fiscal server. A fiscal receipt generated by a PECR has the same legal validity as a receipt issued by a conventional hardware ECR.
After communication is restored, copies of documents generated offline are transmitted to the STS server. According to official STS guidance, they must be transmitted within one hour after the connection is established and before the electronic fiscal report or Z-report for the day on which the documents were created is submitted. The PECR must store these documents until their successful delivery is confirmed.
Is printing a paper receipt mandatory?
No. The law does not require PECR receipts to be issued exclusively on paper.
A business must provide the customer with a payment document in the prescribed form and containing the required information for the full transaction amount. It may be issued in paper and/or electronic form. Permitted methods of providing an electronic document include displaying a QR code on the screen of the device running the PECR or sending the document to the phone number or email address provided by the customer.
The requirements for fiscal receipt formats are established by Ministry of Finance Order No. 13. It remains in force in its version dated January 11, 2025, incorporating amendments introduced by Ministry of Finance Order No. 601. A receipt must contain all mandatory details required by the Regulation. The absence of internet access does not remove these requirements — an offline receipt must also comply with the prescribed format.
Therefore, an internet outage does not, by itself, create an obligation to return to a paper settlement book or install a hardware fiscal register.
What to do during an internet outage, power failure, or PECR malfunction
It is important to distinguish between three different situations.
Internet access or communication with the fiscal server is unavailable, but the device running the PECR is operational. If offline mode is enabled for the PECR and reserved fiscal numbers are available, fiscal sales can continue offline. After communication is restored, the PECR must transmit the documents to the STS and return to online mode.
Power is unavailable, but the PECR can be launched on another functioning device in accordance with its registration details. The law does not treat a power outage as automatically requiring PECR users to switch to a Book of Accounting of Settlement Operations (KOРO). What matters is whether the registered PECR can actually operate and generate a valid fiscal document.
The PECR itself has malfunctioned. A different rule under Article 5 of Law No. 265 applies: transactions cannot be processed through a malfunctioning PECR until the problem is resolved. The STS separately explains that a brief interruption resolved by simply restarting the device is not necessarily considered a malfunction. For an actual malfunction, Procedure No. 317 provides for Form No. 2-PECR.
Different rules apply to hardware ECRs. In the event of a breakdown or temporary power outage, the law allows the use of a Book of Accounting of Settlement Operations (KORO) and a settlement book, or a properly registered backup ECR, for no more than seven working days. This procedure should not automatically be applied to PECRs.
What must be registered before using a PECR?
A PECR is linked to a specific business entity and business unit. Before registering the cash register, the business entity and the relevant facility must be registered with the tax authority. Information about the business unit is submitted in accordance with paragraph 63.3 of the Tax Code, after which an electronic application using Form No. 1-PECR is submitted to the STS.
The application specifies, among other things, how the PECR will operate if communication is lost. If a business owner plans to continue fiscal sales during an internet outage, the PECR must be registered for offline operation and receive a range of reserved fiscal numbers.
Information about the electronic signature or seal certificates used by cashiers on the PECR must be submitted to the STS. Form No. 5-PECR is used for this purpose. Only individuals whose valid certificate details have been entered into the PECR Register may process transactions.
In the current STS electronic document register, Form No. 1-PECR has the electronic identifier J/F1316605, while the notification concerning cashier certificates has the identifier J/F1391802. When configuring third-party PECR software, it is advisable to use an up-to-date version that supports the current STS data exchange formats.
What penalties may apply for improper offline PECR operation?
The mere loss of internet access or a registered PECR's lawful transition to offline mode is not a violation.
Liability may arise if, for example, a business continues accepting payments without a properly functioning PECR, operates offline without a range of fiscal numbers, fails to record the full transaction amount, or does not provide the customer with a valid payment document.
Since August 1, 2025, standard financial penalties have applied to all business entities for violations covered by paragraph 1 of Article 17 of Law No. 265:
| Violation | Financial penalty |
|---|---|
| First established violation — failure to process a transaction through the appropriate ECR/PECR, recording less than the full amount, or failing to provide the required payment document | 100% of the value of goods, work, or services sold in violation of the requirements |
| Each subsequent violation of this kind | 150% of the value of goods, work, or services sold in violation of the requirements |
The STS specifically emphasizes that each sale made without proper use of an ECR/PECR or without issuing a receipt is considered a separate violation rather than one continuous incident.
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 violations of payment processing rules. For a first violation, the fine for the person directly processing payments ranges from 2 to 5 non-taxable minimum incomes of citizens, while for an official it ranges from 5 to 10. For a repeated violation within one year, the respective ranges are 5 to 10 and 10 to 20 non-taxable minimum incomes.
Therefore, during communication outages, it is important not only to have PECR software installed but also to ensure that it is registered for offline operation and actually has unused fiscal numbers available.
Torgsoft PECR: cash register registration, fiscalization of sales, and operation without internet access
Torgsoft supports the use of a software-based ECR directly within its inventory and accounting system. The software documentation describes how to register a business unit, PECR, and cashiers; configure products for fiscal sales; set up receipt printing; use PECR analytics; manage multiple cashiers; reverse transactions; and send receipts to customers. Registration procedures use the company's details and the electronic signature of the business owner or the head of a legal entity.
When creating a PECR, the business unit is selected in Torgsoft, along with the software register type and offline mode support settings. The documentation explicitly states that if offline support is disabled, fiscal receipts cannot be registered when communication with the fiscal server is unavailable. This follows the general principle of Law No. 265: the business owner must either prepare in advance for lawful offline operation or suspend payment transactions until communication is restored.
Torgsoft also provides procedures for changing PECR registration details and deregistering the register. For safe checkout operations, the details of the business unit, PECR, cashiers, electronic signatures, and product fiscal parameters must match the information used by the STS.
Example: how a store operates during an internet outage
A store has opened a shift on a registered PECR with offline mode enabled and a reserved range of fiscal numbers. The internet connection goes down, but the computer or another device continues operating.
The PECR switches to offline mode and assigns each new receipt a number from the reserved range. The receipt indicates that the transaction was processed offline. The customer receives a paper or electronic payment document. After the connection is restored, the PECR returns to online mode and transmits the accumulated documents to the fiscal server. This is the procedure described by the STS in its current questions and answers section concerning software-based ECRs.
In this situation, the business owner does not need to install a hardware ECR or record sales in a paper settlement book simply because the internet connection is unavailable.
What business owners should check before the next connection outage
Before starting work or after changing cash register settings, it is advisable to check:
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whether the business unit for which the PECR is registered is recorded with the STS;
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whether the PECR itself is included in the Software-Based ECR Register;
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whether offline operation was enabled during its registration;
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whether an unused range of fiscal numbers has been obtained for offline sessions;
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whether valid electronic signature or seal certificates for cashiers have been entered into the Register;
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whether the PECR generates receipts correctly, including an indication that the transaction was processed offline;
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whether accumulated offline documents are transmitted to the STS server after communication is restored;
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whether the software version supports the current fiscal document formats.
This approach allows businesses to continue sales during communication outages within the legal framework governing PECRs and reduces the risk of financial penalties for transactions that have not been properly fiscalized.
Official sources
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Law of Ukraine «On the Use of Registrars of Settlement Operations in Trade, Public Catering, and Services» dated July 6, 1995, No. 265/95-VR — Articles 2, 3, 5, 7, and 17; paragraph 13 of Section II, «Final Provisions». Article 5 regulates PECR offline mode, reserved fiscal numbers, and operation during malfunctions; Article 17 establishes the main financial penalties.
Law No. 265/95-VR on the website of the Verkhovna Rada of Ukraine -
Order of the Ministry of Finance of Ukraine dated June 23, 2020, No. 317 «On Amendments to Order No. 547 of the Ministry of Finance of Ukraine dated June 14, 2016» — the Procedure for Registration, Maintaining the Register, and Use of PECRs, particularly Sections II and V. It establishes the registration procedure, rules for using PECRs, and technical procedures for offline operation.
Procedure for Using PECRs 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…» — Sections I–II and fiscal cash receipt form FCR-1. It establishes the mandatory format and details of ECR/PECR fiscal receipts.
Ministry of Finance Order No. 13 on the website of the Verkhovna Rada of Ukraine -
Code of Ukraine on Administrative Offenses — Article 155-1. Establishes administrative liability for cashiers and officials who violate payment processing procedures.
Code of Ukraine on Administrative Offenses on the website of the Verkhovna Rada of Ukraine -
Law of Ukraine dated July 14, 2026, No. 4928-IX «On Approval of the Decree of the President of Ukraine 'On Extending the Duration of Martial Law in Ukraine'» and Decree of the President of Ukraine dated July 13, 2026, No. 596/2026. These documents confirm the extension of martial law for 90 days starting August 2, 2026, which is relevant to the application of paragraph 13 of the Final Provisions of Law No. 265.
Law No. 4928-IX on the website of the Verkhovna Rada of Ukraine -
State Tax Service of Ukraine — «Current Questions and Answers» on Software-Based ECRs. Official explanations concerning the 36/168-hour limits, the martial law exception, reserved fiscal numbers, cashier registration, electronic receipts, and switching between online and offline modes.
Current STS guidance on PECRs -
Ministry of Finance of Ukraine — Interdepartmental Working Group on the Use of PECRs. Official information about the group's status, advisory role, and meetings held.
Interdepartmental PECR Working Group on the Ministry of Finance website
See how stock, documents and payments are connected
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