Fiscal and Non-Fiscal Sales Receipts: Differences and Issuing Rules in Ukraine

If a seller carries out a settlement transaction for which Ukrainian law requires a registrar of settlement transactions (РРО, the Ukrainian abbreviation) or a software registrar of settlement transactions (ПРРО, the Ukrainian abbreviation), the buyer must be given a fiscal receipt. An ordinary non-fiscal sales receipt, payment terminal slip, or delivery note does not replace this obligation. To document a sale correctly, first determine how the money is received, check whether the seller must use an РРО, and prepare documents confirming the purchase contents and transfer of the goods.

A direct transfer to a business account using an international bank account number (IBAN) and payment through card acquiring—the service that lets a seller accept card payments—have different implications for the use of an РРО. Full cash on delivery through NovaPay also requires separate assessment: the Supreme Court found no seller settlement transaction under a specific combination of delivery, payment, and funds-crediting conditions. Each payment method should therefore have its own document-handling procedure.

What a fiscal receipt, non-fiscal sales receipt, and payment slip confirm

A fiscal cash register receipt for goods or services is a settlement document in Form No. ФКЧ-1, generated by an РРО or ПРРО. It contains information about the seller, goods, amount, and payment, and confirms that the relevant settlement transaction was carried out. The definition appears in Section II of the Regulation approved by Ministry of Finance Order No. 13.

A seller issues an ordinary non-fiscal sales receipt to confirm a particular purchase. It can be printed from an accounting program or completed by hand. The presence of the word “receipt,” a barcode, or a list of goods does not by itself mean that the document is fiscalized.

For online sales, keep the documents together under the order number. For example, the invoice explains the purpose of the payment, the bank statement confirms that funds were received, and the goods issue note or non-fiscal sales receipt identifies the goods transferred. Articles 11 and 13 of the Law “On Electronic Commerce” require the buyer to receive confirmation of the electronic transaction and a document confirming receipt of funds, with the settlement date.

The transaction confirmation must state the seller’s name and location, how to submit claims, exchange and return terms, warranty obligations, and information about related services; if the contract has no specified term, it must also explain how to terminate it. The buyer must receive this confirmation when the transaction is concluded or when the seller fulfills the obligation to transfer the goods.

How to determine when a fiscal receipt is required

Start by identifying a settlement transaction as defined in Article 2 of Law No. 265/95-ВР. In retail trade, this includes accepting cash or a payment card from a buyer for goods. Paragraphs 1 and 2 of Article 3 of this Law require such transactions to be carried out for the full amount through a duly registered РРО or ПРРО and a settlement document to be provided to the buyer, unless there is a legal basis for a different procedure.

1. Determine who accepts payment: your cashier, your courier, a bank, or a separate payment service provider.
2. Identify the payment method: cash, card acquiring, direct transfer by IBAN, or cash on delivery under an agreement with a payment institution.
3. Check whether the seller qualifies for an exemption and whether it covers this particular product and business method.
4. Establish which document the seller creates, who gives it to the buyer, and how it is linked to the order.

Cash and card acquiring

If a store accepts cash or card payments through a terminal and must use an РРО, the cashier issues a fiscal receipt. The terminal slip confirms the card transaction, so issuing only that slip leaves the obligation to provide the proper settlement document for the goods unfulfilled. The same analysis applies to goods paid for through online card acquiring: crediting sales proceeds to a bank account does not turn a card payment into an ordinary transfer using bank details.

Direct transfer by IBAN

When a buyer independently transfers money from their account to the seller’s business current account using IBAN details, without the seller accepting cash or a card through acquiring, the seller has no corresponding settlement transaction to process through an РРО. For this type of sale, keep the bank statement and issue a document for the goods.

As a practical measure, send the buyer the recipient’s name, tax number, IBAN, amount, and payment purpose with the order number. Before dispatch, check the bank statement to confirm that the funds have actually been credited to the account. If a link or code opens a card payment page, treat the payment as acquiring, regardless of how the payment method is presented.

Exemptions depend on specific conditions

Article 9 of Law No. 265/95-ВР sets out specific cases where an РРО, ПРРО, and settlement books need not be used. For example, Paragraph 6 concerns individual entrepreneurs (ФОП, the Ukrainian abbreviation) who do not use registrars in accordance with the Tax Code of Ukraine. Merely being a single tax payer is not enough to treat every sale as exempt.

Paragraph 14 of Article 9 concerns settlements for services made exclusively through remote banking systems and/or money transfer services. This provision should not be extended to retail sales of goods. Certain forms of trade under Article 10 may operate without an РРО, but with a settlement book and a book for recording settlement transactions. An ordinary non-fiscal sales receipt does not replace the documents required under that procedure.

Full cash on delivery through NovaPay: applying the Supreme Court’s position

In Case No. 520/27700/25, the Supreme Court upheld cancellation of a fine for the seller’s failure to process transactions through an РРО. The decisive factors were the circumstances taken together: a distance sale, delivery by Nova Poshta, no advance payment of any kind, even partial, payment of the full price by the buyer through NovaPay upon receipt, and subsequent non-cash crediting of the funds to the seller’s business current account.

In those circumstances, the court found that the seller’s receipt of funds from a non-bank institution did not meet the definition of a settlement transaction in Article 2 of Law No. 265/95-ВР. The court specifically emphasized that its conclusion was based on the particular combination of conditions in the case.

The tax service argued for a different interpretation: the seller must generate a fiscal receipt for the goods because NovaPay documents only acceptance of funds for transfer. The supervisory authority maintained this position during the cassation review as well, but the court did not accept it for the transactions at issue. When assessing a similar sale, therefore, consider the court’s conclusion alongside the actual terms of the contracts and payments.

As a practical procedure for full cash on delivery, we recommend:

1. Record in the order that the entire price is payable upon receipt and verify that no advance payment was made.
2. Keep the terms of the delivery and payment service agreements under which the seller operates.
3. Include with the shipment, or give to the buyer, a non-fiscal sales receipt or goods issue note listing the specific goods and seller details.
4. Link the order number to the delivery document, transfer documents, and the credit entry in the bank statement.
5. Reassess the use of an РРО if the payment method, recipient of funds, or contract terms change.

This conclusion does not automatically cover card acquiring, partial advance payments, payments to a personal card, or other contractual arrangements. In addition, the Supreme Court expressly stated that whether documents had been issued and complied with the requirements for form and content was outside the scope of the case. The seller must therefore properly document the goods and transaction even when the funds are not processed through the seller’s own РРО.

How to distinguish the income date from the receipt question

In this ruling, the Supreme Court cited Ministry of Finance letter No. 11220-02-2/93, which states that for the described payment for goods through NovaPay, the date a single tax payer receives income is the date the funds are credited to their account. This clarification concerns when income is received, while the use of an РРО depends on whether a settlement transaction exists. For practical accounting, record the dispatch of goods, the buyer’s receipt of them, and the crediting of funds shown in the bank statement separately. The letter cited in the ruling applies specifically to the described payment through NovaPay. For other payment methods, we recommend checking separately with an accountant when the seller should recognize income.

What details to check on a fiscal receipt

Check the receipt against Paragraphs 2–9 of Section II of Regulation No. 13. The placement of wording in the form is recommended, and whether specific details are mandatory depends on the seller, goods, payment method, and type of registrar.

• Seller and store. The receipt states the seller’s name and the name and address of the business location reported to the State Tax Service of Ukraine (ДПС, the Ukrainian abbreviation) using Form No. 20-ОПП. The store address does not necessarily match the seller’s registered address.
• Tax details. A value added tax (ПДВ, the Ukrainian abbreviation) payer states its individual tax number with the label “ПН.” A non-payer states its tax number with the label “ІД,” or the passport details permitted by the Regulation for a person legally entitled to use them in place of a tax number.
• Goods. The receipt must show the product name, line total, and the letter marking for the VAT rate specified by the form. If the quantity is not equal to one unit of measure, state the quantity and unit price. Repeat the relevant line for each different item.
• Special product details. The code under the Ukrainian Classification of Goods for Foreign Economic Activity (УКТ ЗЕД, the Ukrainian abbreviation), the product barcode, and excise stamp details must be stated in cases required by law. For excisable goods, Paragraph 11 of Article 3 of Law No. 265/95-ВР requires the relevant product data to be programmed.
• Payment. The form provides for the labels “ГОТІВКА” (cash), “БЕЗГОТІВКОВА” (cashless), or “ІНШЕ” (other), the amount by payment type, currency, and means of payment. Repeat the relevant lines when there are several payment types or means. Paragraph 7 of Section II separately states that line 18 is not printed for the payment type “ГОТІВКА”; check the configuration together with this rule.
• Totals and taxes. The receipt states the total cost with the label “СУМА” or “УСЬОГО” (amount or total). A VAT payer shows the rate and VAT amount required by the form; a payer of excise or another applicable tax shows the relevant tax details. The Regulation allows tax-group lines to be omitted if the VAT or excise tax amount is zero.
• Cash rounding. When applied under National Bank of Ukraine rules, the receipt shows “Заокруглення” (rounding) and “До сплати” (amount due), with the amount after rounding. For cash payments, the change and currency are also specified.
• Transaction identification. The receipt must show the fiscal number with the label “ЧЕК №” (receipt No.), the date and time to the second, a two-dimensional QR code for finding the document in the ДПС system, and the registrar’s fiscal number with the label “ФН” or “ФН ПРРО.”
• Registrar details. For a hardware РРО, the form requires the factory number “ЗН” and a message authentication code. For a ПРРО, it requires an online or offline mode label and, in offline mode, a control number as well. A ПРРО factory number is not stated. The form includes the wording “ФІСКАЛЬНИЙ ЧЕК” (fiscal receipt) and a graphic image of the manufacturer’s name or logo.

If a card terminal is connected or integrated with an РРО or ПРРО and actually exchanges data with it, lines 12–17 must be completed: acquirer, merchant, and payment device identifiers; any commission; transaction type; securely displayed electronic payment instrument details; and payment system and authorization details. This condition for completing the lines does not apply to a separate terminal that does not interact with the registrar, but the obligation to issue a fiscal receipt for the goods still applies.

Duty-free shops selling tobacco products and alcoholic beverages must additionally state the special product characteristics and buyer passport details specified by the form. These fields are not a general requirement for every retail store.

A simplified product name may be used by ФОП who are single tax payers and are not VAT payers, within the scope of the permission in Paragraph 2 of Article 3 of Law No. 265/95-ВР. This permission does not cover excisable goods, technically complex household goods subject to warranty repair, medicines, medical devices, or jewelry and household goods made of precious materials as defined by law. The simplified name must reflect the product’s consumer characteristics and unambiguously identify its group under the State Classifier of Products and Services ДК 016:2010. Check the relevant group in this classifier before configuring the product name.

As a practical check, review several real documents: cash payment, card payment, sale of multiple units, mixed payment, and a return. Under Paragraph 3 of Section I of Regulation No. 13, omission of a mandatory detail or failure to meet the document’s intended scope prevents it from being recognized as a settlement document. However, an inaccuracy in the product name that does not distort information about the transaction does not by itself make the receipt a non-settlement document.

How to provide and verify an electronic receipt

Paragraph 2 of Article 3 of Law No. 265/95-ВР permits paper and/or electronic form. The seller may send an electronic settlement document to the phone number or email address provided by the buyer, or display a QR code that allows the document to be scanned and identified. This provision does not establish a general obligation to print a paper copy for every buyer.

Before completing service, the cashier should ask how the buyer wants to receive the receipt, verify the contact details, and ensure the buyer can access the document. Merely saving the receipt in the store’s internal database is not enough to provide it to the buyer. Under Part 11 of Article 8 of Law No. 1023-XII, the document must be issued or created electronically no later than the transfer of the goods or service.

To verify the receipt, open the link in its QR code or use the ДПС fiscal receipt search service. Compare the seller, date, amount, and registrar number. If the document was created by a ПРРО in offline mode, note that it is sent to the fiscal server after connectivity is restored. Article 5 of Law No. 265/95-ВР provides for using a range of fiscal numbers obtained in advance; ordinary non-fiscal printing does not replace this procedure.

How to prepare a non-fiscal sales receipt

There is no single approved form for an ordinary non-fiscal sales receipt comparable to Form No. ФКЧ-1. To make it possible for the buyer and seller to establish what was purchased, we recommend including:

• the title “Товарний чек” (non-fiscal sales receipt), the document number, and date;
• the seller’s full name or ФОП details, tax number, address, and a contact for enquiries;
• a separate name for each item, and, where relevant, model, SKU, or serial number;
• unit of measure, quantity, unit price, and line total for each item;
• the total cost in hryvnias, any discount, and payment details if the document certifies receipt of payment;
• details of the person who prepared the document and a signature for a paper document.

Illustrative example. A buyer purchases two organizers at UAH 240 each and one folder for UAH 90. The seller’s non-fiscal sales receipt shows: 2 × UAH 240 = UAH 480; 1 × UAH 90 = UAH 90; total UAH 570. If the money has not yet been received, the seller should not mark the purchase as paid.

The requirement to provide, on the buyer’s request, a receipt, goods issue note, or other document confirming transfer of ownership is in Paragraph 15 of Article 3 of Law No. 265/95-ВР. It does not cancel the requirement to issue a fiscal receipt where Paragraphs 1 and 2 of that Article apply. At the same time, it is good practice to provide a purchase document right away so the seller, goods, and sale date can be established later.

If the buyer needs documents for the company’s accounting, agree on their preparation before the sale. Before preparing the documents, we recommend asking the buyer’s accountant to check whether they contain enough information about the seller, goods, nature and scope of the transaction, and responsible persons for recording that particular purchase.

What documents to prepare in common situations

For installment payments, we recommend tracking payments by order: total cost, each receipt of funds, its method, document number, and remaining balance. Illustrative example: for a UAH 1,500 order, the buyer pays a UAH 400 advance; the balance is UAH 1,100. The documents must make both payments traceable so the seller does not miss a settlement or count the same amount twice.

How to accept goods for exchange or return

Buyers’ rights in Ukraine are defined by Articles 8 and 9 of Law No. 1023-XII “On Consumer Rights Protection”. The general entry into force of Law No. 3153-IX is postponed at least until martial law is terminated or cancelled, pursuant to Paragraph 1 of its final and transitional provisions. The procedure for handling requests should therefore be based on the applicable provisions of Law No. 1023-XII.

1. Establish the reason for the request. For a good quality non-food product, Article 9 provides for exchange within 14 days, excluding the day of purchase, unless the seller has announced a longer period. The product must be unused and retain its properties, appearance, seals, and labels. Also check the list under Resolution No. 172 of goods of good quality that cannot be exchanged or returned.
2. Establish the purchase. Accept a paper or electronic settlement document for review. For warranty claims, consider the documents on warranty and sale date required under Article 8.

3. Determine the applicable remedy. If a good quality product is eligible for exchange but no equivalent is available, the buyer has the choices provided in Article 9, including a refund. If the buyer finds a defect during the warranty period, Article 8 provides for a proportionate price reduction, free repair, or reimbursement of repair costs. The buyer may demand termination of the contract with a refund, or replacement of the goods, if the goods are found during the warranty period to have a substantial defect caused by the manufacturer, seller, or service provider, or to be counterfeit.

   If needed, these circumstances are confirmed by an expert opinion. An unfit food product follows a different rule: the seller must replace it with one fit for consumption or refund the money paid.

4. Document the outcome. Record the goods, quantity, reason, amount, and link to the original sale. If the refund is a settlement transaction that requires an РРО or ПРРО, issue a fiscal refund receipt in Form No. ФКЧ-2 in accordance with Section III of Regulation No. 13. When a contract is terminated under Article 8 or 9 of Law No. 1023-XII, the seller refunds the money on the day of termination, or, if that is impossible, within a period agreed with the buyer, but no later than seven days.

   Under Article 9, calculate the settlement using the goods’ value at the time of purchase; under Article 8, if the price has increased, use the value when the request is made, and if it has decreased, use the value at the time of purchase.

If the buyer has lost the paper receipt, first help find the electronic document or restore the sale details in your system. The search may require the date, approximate time, amount, product name, order number, bank statement, or correspondence. These materials help establish the purchase and may be evidence in a dispute, but not all of them automatically replace a settlement document expressly required under Articles 8 and 9.

For distance sales, also apply Article 13 of Law No. 1023-XII. The buyer may notify the seller of termination within 14 days from confirmation of the information or receipt of the goods or first delivery. If the confirmation does not meet the requirements of Part 3 of that Article, the buyer has 90 days to terminate the contract: for a tangible product, this period runs from receipt of the goods or first delivery; in other cases, it runs from receipt of that information.

If the seller corrects the confirmation within that period, the buyer has 14 days from receipt of the corrected confirmation. Check the exceptions in Part 5: for example, for goods made or modified to order, the exception applies if they cannot be sold to another person or can be sold only at a significant financial loss to the seller. The words “made to order” alone are not enough.

Part 7 of Article 13 applies Parts 5–9 of Article 12 to such contracts: the seller bears the return costs. The buyer must keep the goods in an unchanged condition, but opening the packaging, inspecting or checking the goods, and any resulting reduction in value do not remove the right to terminate the contract. That right is also retained if the goods are destroyed, damaged, or spoiled through no fault of the buyer.

Before refusing the buyer, therefore, check the reason for the request and the relevant statutory conditions.

What fine applies for failing to issue a fiscal receipt

For violations listed in Paragraph 1 of Article 17 of Law No. 265/95-ВР, including failure to process a settlement transaction through an РРО or ПРРО, processing it for less than the full amount, or failing to provide a proper settlement document, the financial penalty is 100% of the sale amount for the first violation and 150% for each subsequent violation.

Illustrative example: if the sale amount involved in the violation is UAH 800, the penalty for the first violation is UAH 800, and for a subsequent violation involving the same amount it is UAH 1,200. The temporary reduced rates of 25% and 50% provided for in Paragraph 15 of the final provisions do not apply to current transactions.

Paragraph 14 of the final provisions provides a territorial exemption from liability under its specified conditions, except for violations involving sales of excisable goods. It concerns sales in temporarily occupied territories and territories of active or possible hostilities, together with the relevant dates in the official list. Check the location and date of each sale. This exemption from liability does not cancel the statutory procedure for processing settlements.

Non-fiscal sales receipts and fiscal receipts in Torgsoft: configuring sales documents

Torgsoft’s “Реалізація” (“Sale”) mode has separate actions for printing a non-fiscal receipt, goods issue note, and invoice. The owner should determine which document the cashier uses for each payment method and check the non-fiscal sales receipt template for seller details, goods, quantities, and amounts. Note the behavior of the “Не фіскальний чек” (“Non-fiscal receipt”) action: according to Torgsoft’s instructions, for a new sale it shows the payment as cash, and for a sale open for editing it shows the payment according to the completed payment.

Before issuing the document, check that it reflects the actual payment method. Ordinary printing from the program does not confirm processing through an РРО. If a transaction must be fiscalized, the relevant workstation needs a properly configured and duly registered hardware or software fiscal registrar; available program features and workstations should be checked against the terms of the selected Torgsoft license. Verify the result using the fiscal document actually generated and the ДПС data.

For buyer requests, Torgsoft supports finding a sale for a return by barcode or numeric receipt code, as well as selecting a sale and finding goods without a receipt. In practice, this helps locate the original purchase and record the quantity being returned. Check the “Максимальний термін повернення” (“Maximum return period”) setting in the general settings: the program uses it when processing a return and selecting sales.

If the setting prevents a buyer from exercising a legal right, agree on a change with the responsible employee; the period in the program does not define the buyer’s rights. For full cash on delivery that meets the Supreme Court’s conditions for finding no seller settlement transaction, keep proper goods and payment documents. Having an accounting program or fiscal equipment does not by itself create an obligation to fiscalize such a receipt of funds.

Official sources for checking documents

• Law No. 265/95-ВР: Articles 2, 3, 5, 9, 10, and 17; Paragraphs 14 and 15 of the final provisions.
• Regulation No. 13 on the form and content of settlement documents: Sections I–III and VI.
• Supreme Court ruling in Case No. 520/27700/25: conditions for full cash on delivery through NovaPay and limits of the court’s conclusion.
• Law No. 1023-XII “On Consumer Rights Protection”: Articles 8, 9, 12, and 13.
• Law No. 3153-IX: conditions for entry into force in the final and transitional provisions.
• Law “On Electronic Commerce”: Articles 7, 11, and 13.
• Resolution No. 172 of the Cabinet of Ministers of Ukraine: list of goods of good quality that cannot be exchanged or returned.