RRO/PRRO for Online Stores and Acquiring

RRO/PRRO for online stores, acquiring, and cashless payments

For an online store, the decisive factor is not the fact of selling through a website itself, but the payment method. If the buyer pays by card, via internet acquiring, a "Pay" button, a payment link, a POS terminal, a mobile wallet, or another electronic payment instrument, this is considered a settlement operation, and therefore the seller must use an RRO or PRRO and issue a fiscal receipt. The fact that the payment is cashless does not in itself exempt from the RRO. (Legislation of Ukraine)

An RRO or PRRO may not be needed when the buyer independently transfers funds to the seller's account in IBAN format: from their account to the seller's account via a bank, online banking, a bank cashier, or via a PTKS (self-service terminal) belonging to a bank. Separately, the law exempts from the RRO the payment for services through banking systems of remote service and/or funds transfer services. A separate exception applies to sole proprietors (FOPs) on the 1st group of the single tax. The buyer must still receive a proper settlement document if the operation is a settlement one, including in e-commerce. For failing to process an operation through an RRO/PRRO or not issuing a receipt, fines are currently 100% of the violation amount for the first time and 150% for each subsequent violation. (dp.tax.gov.ua)

Main rule: when RRO/PRRO is mandatory

Law No. 265 applies to business entities that carry out settlement operations in cash and/or cashless form using electronic payment means, payment checks, tokens, etc. That is why the phrase "we have cashless payment" does not mean that an RRO is not needed. If cashless payment passes through a card or another electronic payment instrument, it falls under the rules of Law No. 265. (Legislation of Ukraine)

The law on payment services distinguishes a payment operation, a payment instrument, an electronic payment means, and a credit transfer. In practice, this means the following: paying by card or through acquiring is one model, while an independent transfer to an IBAN is another. The approach to RRO in online stores is built precisely on this difference. (Legislation of Ukraine)

Which payments in an online store require RRO/PRRO

When it is possible without RRO/PRRO

What is important to understand about acquiring

Acquiring is not just "money entered the account". For RRO purposes, it is important that the payment is initiated through an electronic payment means or another payment instrument, and the law explicitly includes such cashless settlements in the scope of RRO application. Therefore, the wording "acquiring is cashless, so a receipt is not needed" is erroneous. (Legislation of Ukraine)

In practice, this means that most B2C online stores that accept card payments on the site actually work in a mode where an RRO/PRRO is required. Models where the buyer does not pay the seller by card, but independently makes a bank transfer to an IBAN, usually operate without an RRO. (dp.tax.gov.ua)

Receipt in an online store: when and how to issue it

The business entity is obliged to provide the person receiving the goods or services with a settlement document of the established form and content for the full amount of the operation. This obligation explicitly applies to orders or payments made using the Internet. The document can be paper or electronic, in particular via a QR code, e-mail, or the buyer's phone number. (Legislation of Ukraine)

For delivery by mail, courier, or to a pick-up point, it is important to organize the process so that the buyer receives the seller's exact settlement document at the appropriate moment. If post-payment is used, the form and means of payment in the fiscal receipt must correspond to the actual method of settlement. The tax authority directly provides a separate rule for filling out lines 18 and 19 of the receipt for such cases. (Legislation of Ukraine)

What payment details are displayed in the fiscal receipt

The tax authority explains that line 18 of the fiscal receipt indicates the form of payment, and line 19 indicates the specific payment means. For an online store, this is especially important, because the receipt must correctly distinguish, for example, internet acquiring, card transfer, QR transfer, internet banking, payment service, or post-payment. Incorrect display of the payment method creates risks during an inspection. (od.tax.gov.ua)

Documents that an online store must have

On the site or in another information system, the seller must provide direct, simple, and stable access to at least their identification information. The law directly names the full name of the legal entity or the full name of the FOP. An electronic contract concluded through a website has the same legal force as a contract in another form, provided the legal requirements are met. (Legislation of Ukraine)

For an online store, a basic set of documents in practice includes: a public offer or terms of sale, payment and delivery policy, return policy, personal data processing procedure, fiscal receipts for settlement operations, and documents on the origin of goods. The actual requirement for seller identification, electronic contract, and legality of settlements directly follows from the E-Commerce Law. (Legislation of Ukraine)

Inventory accounting and supporting documents

Law No. 265 obliges business entities to keep records of inventory and provide during an inspection documents confirming the accounting and origin of the goods that are at the place of sale. At the same time, there is an exception for some FOP single tax payers without VAT, but it does not apply, in particular, to the sale of technically complex household goods, medicines, medical devices, and jewelry. For an online store, this means that documents for goods and internal accounting must be kept in order not only for tax accounting but also for protection during actual inspections. (Legislation of Ukraine)

Licenses, permits, special goods

Selling through a website does not by itself create a separate license just because of the online format. But if the law requires a license or permit document for a specific product or service, they can be sold in e-commerce only after obtaining such a license or permit. An online store does not remove requirements for a special regime for the circulation of goods, storage, labeling, personnel, or other specialized rules. (Legislation of Ukraine)

Therefore, for alcohol, tobacco, medicines, medical devices, jewelry, technically complex household goods, and other regulated products, it is necessary to check not only Law No. 265 but also special profile acts. The "online store" format provides no privileges here. (Legislation of Ukraine)

Personal data of buyers

An online store almost always processes personal data: name, phone number, delivery address, e-mail, sometimes payment details. The law requires that the purpose of processing personal data be defined and comply with the law, and the processing itself takes place openly and transparently. The basis for processing can be the consent of the data subject or another lawful basis defined by law. (Legislation of Ukraine)

This means that the seller must have a clear privacy policy, describing the purpose of data collection and the legal grounds for its use in ordering, delivery, payment, return, and communication with the client. (Legislation of Ukraine)

Taxes: what is important for FOPs

For FOPs on a single tax who accept payment via acquiring and process it by issuing a fiscal receipt, the tax authority separately notes in the knowledge base: the income is the entire amount of revenue, including the bank commission, and the date of receipt of income is the date specified in the fiscal receipt. This is important for those who mistakenly focus only on the amount that actually entered the account after deducting the acquirer's commission. (zir.tax.gov.ua)

Fines and risks

As of today, for failing to process a settlement operation through an RRO/PRRO, processing it for an incomplete amount, or failing to issue a settlement document, financial sanctions apply: 100% of the sale amount with the violation — for the first violation and 150% — for each subsequent one. Separately, fines are provided, in particular, for violating the rules of use or storage of KURO/settlement books, if they are used. (Legislation of Ukraine)

The riskiest situations for an online store: accepting payment on the site without fiscalization, using the details of the seller's card instead of the IBAN account, confusion between an IBAN transfer and internet acquiring, not issuing a receipt upon delivery, lack of documents for the goods, and incorrect indication of the form or means of payment in the fiscal receipt. (dp.tax.gov.ua)

How to use a software RRO in e-commerce in Torgsoft?

The Torgsoft program automates complex scenarios for working with a software RRO (pRRO), which are mandatory for conducting e-commerce according to the requirements of the State Tax Service (DPS). Work with online orders is most often carried out through the "Trade with invoicing" mode, where you can flexibly configure work with prepayments, post-payments, and electronic receipts.

Here is a detailed guide on using pRRO for e-commerce in Torgsoft:

Official sources

Програма обліку товару для інтернет-магазинів, крамниць, торгових точок, складів та виробництва