PRRO for online stores: receipts, COD and returns

PRRO, fiscal receipts, cash on delivery and returns in an online store: rules for entrepreneurs

For an online store, the obligation to use an RRO or PRRO depends not on the mere fact of selling through a website, social media or marketplace, but on the payment method. If the seller accepts cash, payment by payment card, online acquiring or another payment instrument, the payment usually has to be processed through an RRO/PRRO. If the buyer independently transfers funds to the seller’s current account using IBAN details without card acquiring, RRO/PRRO is not used. For cash on delivery, the decisive factors are the contract with the carrier, the person who accepts money from the buyer, and the method of further transferring funds to the seller.

There is no single rule to «generate a receipt before shipping the goods». For card prepayment, the receipt is generated at the time of payment. If the money is accepted by the seller’s own courier, the receipt is issued at the time of payment upon delivery. If the goods are delivered by a forwarder who is not a party to the sales contract and does not process the payment on their own behalf, the seller must ensure that its fiscal receipt is provided before or no later than the moment the buyer receives the goods. If the parcel is not collected, the procedure depends on whether the money was received and whether the seller generated the initial fiscal receipt.

When an online store needs an RRO or PRRO

Law No. 265/95-VR requires payment transactions to be processed through a registered RRO/PRRO for the full purchase amount and requires the buyer to be provided with a payment document in the established form. This requirement also applies to goods ordered or paid for via the Internet. The receipt may be paper or electronic.
Payment transactions include, in particular:

• accepting cash;

• payment by payment card through a POS terminal;

• card payment on the website through online acquiring;

• accepting payment by the seller’s own courier;

• returning cash or funds from a card transaction to the buyer;

• other transactions using payment instruments that, by their nature, meet the definition of a payment transaction.

The name of the payment method on the website does not determine the obligation to use PRRO. It is important to establish exactly how the buyer initiates the payment and who accepts the funds.

When RRO/PRRO is not used

RRO/PRRO, in particular, is not required in the following cases:

1. The buyer transfers funds directly to the seller’s current account using IBAN details. This must be an ordinary bank transfer to a business account, not card payment through acquiring or a payment page.

2. The sole proprietor is a first-group single tax payer. Such entrepreneurs are exempt from using RRO/PRRO under clause 296.10 of the Tax Code.

3. There is actually no payment transaction. For example, funds are received by the seller from the postal operator’s account after the operator itself accepted cash on delivery from the buyer and issued its own fiscal receipt under the contract.

4. Services are provided, and settlements for them are made exclusively through remote banking systems or money transfer services. The exception in clause 14 of Article 9 of Law No. 265 applies specifically to services. It cannot be automatically applied to the sale of goods.

A transfer to a sole proprietor’s personal card is not a proper substitute for a business current account and does not automatically create an exemption from RRO/PRRO.

How to fiscalize different payment and delivery methods

The rules for cash on delivery must be set out in the contract with the carrier. The contract and actual flow of funds must make it clear:

• whether the carrier accepts money on its own behalf;

• whether it issues a fiscal receipt to the buyer;

• to which account and on whose behalf the funds are transferred;

• whether the carrier acts only as a forwarder;

• who is responsible for providing the buyer with the fiscal and accompanying goods documents.

When to generate a receipt for card prepayment

If the buyer paid for the order by card through the website, a payment link or online acquiring, the seller must process the payment transaction through RRO/PRRO at the time of payment.

The receipt can be:

• sent by email;

• sent to a phone number;

• provided through the buyer’s personal account;

• placed in the parcel in paper form;

• provided by displaying a QR code that allows the receipt to be identified.

Paper and electronic fiscal receipts have the same legal force. Placing a paper receipt in the parcel does not exempt the seller from timely processing of the transaction itself through PRRO.

Receipt for deferred payment and delivery by a forwarder

When the buyer receives goods with deferred payment, and the forwarder only delivers the parcel and is not a party to the settlement, the seller must ensure that the payment document is provided before or no later than the buyer receives the goods.

The receipt must indicate the payment form that corresponds to the real terms of the contract. It is not allowed to indicate «cash» or «card» if the funds have not yet been received. If the software provides a payment form such as «credit», «deferment», «cash on delivery» or another appropriate designation, it must correspond to the substance of the contract and the actual transaction.

Therefore, generating a receipt before shipment may be a safe organizational solution for a specific delivery model, but legislation does not establish it as the only procedure for all online sales.

What details a fiscal receipt must contain

The form and content of fiscal receipts are determined by Order No. 13 of the Ministry of Finance of Ukraine. An online store receipt must contain the established mandatory details, in particular:

• seller’s name or sole proprietor’s details;

• tax number;

• name of the business unit;

• address of the place where settlements are made;

• name of the product that allows it to be identified;

• quantity, price and value of the goods;

• total transaction amount;

• form and means of payment;

• tax rates and amounts — if applicable;

• date and time of the transaction;

• fiscal receipt number;

• QR code and other details provided by the form.

If a mandatory detail is missing, the document may not be recognized as a payment document. A minor error in the product name that does not distort the substance of the transaction and allows the product to be identified should not by itself make the receipt invalid.
A payment terminal receipt, bank notification, bank statement or payment service receipt confirms payment, but does not replace a fiscal receipt when the transaction must be processed through RRO/PRRO.

Payment in installments: prepayment, next payment and final settlement

Each part of the payment that is a payment transaction is processed through RRO/PRRO separately.

The following designations may be used in PRRO:

• «Prepayment»;

• «Next payment»;

• «Final settlement».

During the next or final payment, it is advisable to indicate the amount previously paid, the current payment, the balance and the fiscal number of the receipt by which the prepayment was documented.

Example

The buyer paid 30% of the price by card on the website, and 70% must be paid upon receipt:

1. For 30%, the seller immediately generates a receipt through PRRO.

2. If the remainder is accepted by the seller’s own courier in cash or by card, the seller generates a second receipt during delivery.

3. If the remainder is accepted by the postal operator on its own behalf and it issues its own receipt, the procedure for fiscalizing this part is determined by the contract with the operator.

4. If the remainder is transferred directly to the seller’s current account by IBAN, PRRO is not used for this part.

There is no need to generate a fiscal receipt merely because the buyer paid part of the funds if that part was received by ordinary bank transfer by IBAN and is not a payment transaction within the meaning of Law No. 265.

If the buyer did not collect the parcel

The procedure depends on the initial transaction.

1. Cash on delivery was not paid, the seller did not receive money and did not generate its own receipt

If cash on delivery was to be accepted by the postal operator, the buyer did not collect the goods, no funds were received by the seller and the seller did not generate a fiscal sales receipt, there are no grounds to issue an expense receipt for refunding money.

The following should be kept:

• carrier’s waybill or receipt for the return;

• document for the initial shipment;

• internal document on returning the goods to the warehouse;

• correspondence or notification from the buyer — if available;

• documents confirming the absence of cash-on-delivery proceeds.

2. The seller generated a sales receipt or deferred payment receipt

If the seller has already generated a fiscal receipt and the goods were returned due to the buyer’s refusal, a return transaction must be processed through PRRO on the basis of:

• the initial fiscal receipt;

• the carrier’s waybill, receipt or other document confirming the return;

• a document that allows the specific order and product to be identified.

According to the clarification of the State Tax Service, such a transaction is carried out on the day documents about the return are received from the delivery service, and if this is impossible due to the work schedule — on the next working day.

3. The buyer made a prepayment that must be refunded

If the funds were received and fiscalized, the seller issues an expense fiscal receipt and refunds the money to the buyer.

If the prepayment was received by ordinary transfer by IBAN and PRRO was lawfully not used, the refund is made by bank transfer without generating a fiscal receipt, with proper documentary registration.

How to process the return of paid goods

When goods are returned and money is issued to the buyer through RRO/PRRO, an expense receipt is generated — a fiscal cash receipt for issuing funds, form FKCH-2.

Main rules:

1. The return is registered as a negative transaction through the return function.

2. The transaction cannot be corrected by ordinary «storno» if the software does not generate a proper fiscal return document.

3. The expense receipt must identify the initial sales receipt.

4. The form of refund must correspond to the initial payment method: cash is returned as cash, a card payment — to the relevant payment instrument, unless otherwise follows from legislation and the rules of the payment service provider.

5. The buyer’s application or another document on the basis for the return, the initial receipt, the expense receipt and documents on the actual transfer or issuance of money must be kept.

When an act on issuing funds is required

If the refund amount exceeds 100 hryvnias, an act on issuing funds is prepared. The act states:

• details of the buyer’s identity document, if they are actually obtained on a lawful basis;

• information about the product;

• refund amount;

• number, date and time of the initial payment document;

• reason for the return.

The act is transferred to accounting and kept for the established period. For a sole proprietor without accounting, the act is kept by the entrepreneur personally.

If the buyer did not pay money and the seller does not return anything to them, no act on issuing funds is prepared. The mere fact that the carrier returns an unpaid parcel is not an issuance of money to the buyer.

The consumer’s right to return goods and fiscal registration are different procedures

As of 22 July 2026, Law of Ukraine No. 1023-XII «On Consumer Rights Protection» remains in force. The new Law No. 3153-IX has not yet entered into force.

Under a distance contract, as a general rule, the consumer may notify about its termination within 14 days from the moment of confirmation of pre-contractual information or receipt of the goods. The law provides exceptions, in particular for goods manufactured or processed to an individual order if they cannot be sold to another person or this would cause significant financial losses.

The existence of the consumer’s right to return does not cancel the need to:

• accept the goods under a proper document;

• process the refund;

• generate an expense fiscal receipt if the initial payment was processed through RRO/PRRO;

• adjust goods, tax and accounting records.

Date of income of a sole proprietor when paying by card

Clause 292.6 of the Tax Code defines the date of income receipt by a single tax payer as the date funds are received in cash or non-cash form.

For practical accounting, payment methods must be distinguished.

Cash

Income arises on the day cash is actually received.

Ordinary transfer by IBAN

Income arises on the day funds are credited to the sole proprietor’s current account.

Card payment through a POS terminal or online acquiring

The State Tax Service, referring to the position of the Ministry of Finance, explains that for a sole proprietor — single tax payer, the date of income for a card transaction is the date indicated in the fiscal receipt, not the later date of actual crediting of funds by the acquiring bank. The full amount paid by the buyer is included in income, without reduction by the bank commission.

Example

The buyer paid for the goods by card on 30 December. The fiscal receipt was generated on 30 December, and the bank credited the funds to the seller on 3 January. Under the approach of the State Tax Service, the sole proprietor’s income is recorded on 30 December in the full payment amount, including the acquirer’s commission.

For atypical payment models, aggregators, marketplaces or long transit accounts, it is advisable to obtain an individual tax consultation describing the contracts and flow of funds.

How a return affects the single tax

Amounts of advance payment or prepayment that a sole proprietor returns to the buyer due to return of goods, termination of the contract or on the basis of a refund application are not included in income under subclause 5 of clause 292.11 of the Tax Code.

If the receipt and return of funds took place in the same reporting period, the returned amount is not reflected as final income.

If the money was included in income in one reporting period and returned in another, the State Tax Service in its current ZIR clarification requires amending the previously filed declarations in which this amount was included. The refund must be confirmed by primary documents and the actual flow of funds.

Return by a VAT payer

If the seller is a VAT payer, the return of goods or prepayment requires not only fiscal registration, but also VAT adjustment.

Under Article 192 of the Tax Code, the seller prepares an adjustment calculation to the tax invoice. According to the clarification of the State Tax Service, if the dates of the buyer’s actual return of the goods and the seller’s receipt of them differ, the adjustment calculation is prepared on the date the seller receives the goods or on the date the funds are returned — depending on which event occurred earlier.

The fiscal expense receipt does not replace the adjustment calculation to the tax invoice, and the adjustment calculation does not replace fiscal registration of the refund.

Documents an online store must keep

For each sales model, a complete documentary chain must be ensured from the purchase of goods to their sale, delivery and possible return.

The main documents include:

• contracts with suppliers;

• outgoing and incoming delivery notes;

• consignment notes;

• customs declarations — for imported goods;

• purchase acts and other documents on the origin of goods;

• contracts with banks, acquirers, payment services, marketplaces and carriers;

• bank statements;

• acquiring registers;

• fiscal sales and return receipts;

• Z-reports and other PRRO documents;

• postal and express waybills;

• receipts for issuing or returning a shipment;

• buyers’ applications;

• acts on issuing funds;

• documents on returning goods to the warehouse;

• warranty documents;

• certificates, declarations of conformity, licenses and permits — if they are required for the specific product.

On each day when payment transactions were carried out, the RRO/PRRO must generate a fiscal reporting receipt — a Z-report.

Retention periods depend on the type of document and the taxpayer’s status. For most tax documents of sole proprietors, a period of at least 1095 days applies, but the Tax Code also provides periods of 1825 and 2555 days for certain categories of documents and transactions. Documents related to an audit, administrative or court dispute cannot be destroyed until the relevant procedure is finally completed.

An electronic archive and backup do not replace compliance with statutory retention periods, but help restore documents in case of technical failure, loss of equipment or audit.

Inventory accounting

The entrepreneur must have documents confirming the origin, purchase, movement and accounting of goods. At the beginning of an audit, documents may be provided in paper or electronic form.

Documents on inventory may include:

• suppliers’ delivery notes;

• consignment notes;

• customs declarations;

• purchase acts;

• suppliers’ fiscal or sales receipts;

• documents on internal movement;

• inventory lists;

• documents on return of goods from the buyer.

For selling unaccounted goods or failure to provide documents on their accounting, Article 20 of Law No. 265 provides for a financial sanction in the amount of the value of such goods at sales prices, but not less than ten non-taxable minimum incomes of citizens.

This sanction does not apply to sole proprietors — single tax payers who are not VAT payers, except sellers of:

• technically complex household goods subject to warranty repair;

• medicinal products;

• medical devices;

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

Exemption from the sanction under Article 20 does not mean that the entrepreneur may sell goods without documents on their lawful origin.

Registration of PRRO and place of activity

Before starting settlements, it is necessary to:

1. Notify the State Tax Service about the business unit or another taxable object using form No. 20-OPP, if the obligation to submit such notification arises.

2. Register the PRRO for the relevant business unit.

3. Ensure that the name and address of the business unit correspond to the data submitted to the State Tax Service.

4. Register the persons who will work with PRRO and properly organize the use of electronic signatures or seals.

5. Program goods, prices, tax groups and payment forms.

6. Check the generation of sales, prepayment, final settlement and return receipts.

7. Determine the procedure for working when there is no connection to the fiscal server.

The address and name of the business unit in the receipt must correspond to the documents confirming ownership or use of the premises and the accounting data in the State Tax Service.

Information that must be on an online store website

The seller must provide buyers with direct, simple and stable access to the following information:

• full name of the legal entity or surname, first name and patronymic of the sole proprietor;

• location of the legal entity or place of registration and actual residence of the sole proprietor;

• email address or online store address;

• tax number;

• license information, if the activity is licensed;

• information about inclusion of taxes in the price;

• delivery cost and conditions;

• payment procedure;

• procedure for accepting complaints;

• main product characteristics;

• warranty conditions;

• procedure for returning goods and terminating the contract.

The person who received payment under an electronic contract must provide the buyer with an electronic document, receipt, sales or cash receipt or another document confirming receipt of funds and containing the date of settlement.
A fiscal receipt confirms the payment transaction, but does not replace complete information about the seller, goods, delivery, warranty and contract terms.

Licenses, labeling and special goods

The law does not establish a separate universal license solely for opening an online store. However, if the sale of specific goods is subject to licensing or requires a permit, they may be sold online only after obtaining the relevant license or permit. License information must be posted on the website.

Special requirements may apply, in particular, to:

• alcoholic beverages;

• tobacco products and liquids for electronic cigarettes;

• fuel;

• medicinal products;

• medical devices;

• food products;

• jewelry;

• technically complex household goods.

PRRO does not replace a license, permit, state registration of capacity, declaration of conformity, product safety documents or mandatory labeling.

For excisable goods, the receipt uses programming indicating the commodity subcategory code according to the Ukrainian Classification of Goods for Foreign Economic Activity. For alcoholic beverages, the legally required data of the excise tax stamp are also indicated.

Premises, warehouse, storage conditions, personnel and transportation must meet the special requirements for the specific type of product. The status of an online store itself does not exempt from these requirements.

Personal data of buyers

An online store may collect only those personal data that are needed to process an order, payment, delivery, warranty service and other lawful purposes.

The website must define:

• the purpose of data processing;

• the list of data collected;

• the legal basis for processing;

• persons to whom the data are transferred, including carriers and payment providers;

• retention periods;

• procedure for exercising the buyer’s rights;

• data protection measures.

It is prohibited to use data obtained for fulfilling an order for other purposes without a proper legal basis.

Fines for violating RRO/PRRO rules

The main financial sanctions are established by Articles 17 and 20 of Law No. 265.

Reduced sanctions of 25% for the first and 50% for subsequent violations, which temporarily applied to certain sole proprietors — single tax payers, were valid only until 31 July 2025. In 2026, the general rates of 100% and 150% apply.

Control is carried out through factual and documentary audits. Employees and officials may also be held administratively liable.

Violation of RRO/PRRO rules in itself is not a universal ground for «cancelling an online store permit», because there is no general permit for such activity. For licensed goods, consequences, including suspension or cancellation of a license, are determined by separate sectoral laws.

Practical operating procedure for an online store

Before starting sales, it is necessary to:

1. Describe all payment methods and fund flows.

2. Separate IBAN transfers from card acquiring.

3. Check contracts with carriers, marketplaces and payment services.

4. Determine who generates the receipt for each cash-on-delivery model.

5. Register business units, PRRO and cashiers.

6. Set up the current receipt form in accordance with Order No. 13.

7. Program product names, prices, tax groups and UKT ZED codes for excisable products.

8. Automate sending electronic receipts to buyers.

9. Establish separate procedures for prepayment, partial payment, cash on delivery, refusal of a parcel and refunding money.

10. Ensure daily generation of the Z-report when payment transactions are present.

11. Organize accounting of goods and documents on their origin.

12. Create an electronic archive of receipts, delivery notes, bank statements and carrier documents.

13. Train employees not to delete or «storno» fiscal transactions without proper return processing.

14. Periodically reconcile PRRO, bank, acquiring, delivery service, warehouse accounting and tax reporting data.

Official sources

1. Law of Ukraine «On the Use of Registrars of Payment Transactions in Trade, Catering and Services» dated 06.07.1995 No. 265/95-VR — Articles 2, 3, 9, 15, 17, 20, 25, 26; clause 15 of Section II.
   https://zakon.rada.gov.ua/laws/show/265/95-%D0%B2%D1%80

2. Tax Code of Ukraine dated 02.12.2010 No. 2755-VI — Articles 44, 192, 292; clause 296.10.
   https://zakon.rada.gov.ua/laws/show/2755-17

3. Order of the Ministry of Finance of Ukraine dated 21.01.2016 No. 13 «On Approval of the Regulation on the Form and Content of Payment Documents/Electronic Payment Documents…» — Sections I–III, forms FKCH-1 and FKCH-2.
   https://zakon.rada.gov.ua/laws/show/z0220-16

4. Order of the Ministry of Finance of Ukraine dated 14.06.2016 No. 547 «On Approval of Procedures for Registration and Use of RRO and Books of Payment Transaction Records» — procedure for processing returns and acts on issuing funds.
   https://zakon.rada.gov.ua/laws/show/z0918-16

5. Law of Ukraine «On Electronic Commerce» dated 03.09.2015 No. 675-VIII — Articles 5, 7, 11, 13, 14.
   https://zakon.rada.gov.ua/laws/show/675-19

6. Law of Ukraine «On Consumer Rights Protection» dated 12.05.1991 No. 1023-XII — Articles 8, 9, 13, 15, 17, 23.
   https://zakon.rada.gov.ua/laws/show/1023-12

7. Law of Ukraine «On Personal Data Protection» dated 01.06.2010 No. 2297-VI — Articles 6, 8, 11, 24.
   https://zakon.rada.gov.ua/laws/show/2297-17

8. Clarifications of the State Tax Service on the use of RRO/PRRO in online trade and different delivery and cash-on-delivery methods.

9. Clarifications of the State Tax Service on the date of income of a sole proprietor when paying through a POS terminal and online acquiring.

10. Public Information and Reference Resource of the State Tax Service: processing a return if the buyer refused a postal shipment.

11. Clarifications of the State Tax Service on issuing an expense receipt when returning goods.

12. Public Information and Reference Resource of the State Tax Service: prepayment, next payment and final settlement through PRRO.