RRO and PRRO for Sole Proprietors and Trade: Operating Rules

RRO and PRRO for sole proprietors and businesses: a complete guide

RRO and PRRO are not a separate "tax system" but an instrument for the fiscalization of settlements. The general rule in Ukraine is: if a business entity conducts settlement operations in the field of trade, catering, or services, it is obliged to conduct them through a registered RRO or registered PRRO for the full amount of the purchase or service and issue a settlement document of the established form to the buyer. This rule applies to both cash and a significant part of non-cash settlements if they have the characteristics of a "settlement operation" within the meaning of the Law. (Law of Ukraine)

For sole proprietors on the simplified system, the main exception expressly preserved in the Tax Code is single tax payers of the first group. They are the ones who do not use RRO/PRRO. For other sole proprietors and legal entities, the issue is not decided by the old "million" rules, but by the fact of whether you have settlement operations and whether you fall under a specific exception from the law or the government list. (Law of Ukraine)

Who must use an RRO or PRRO

RRO/PRRO are required by a store, cafe, salon, service company, online store, delivery service, showroom, pharmacy business, workshop, and any other business that accepts cash, payment cards, POS-terminal payments, internet acquiring, or other electronic payment means from a buyer within a settlement operation. If money is accepted "from a client for a product or service" in a way that the law considers a settlement, fiscalization is required. (Law of Ukraine)

Special attention should be paid to excisable goods, technically complex household goods subject to warranty repair, medicines, medical devices, and jewelry. For these categories, the law contains stricter rules regarding inventory accounting, product programming in the receipt, and exceptions for single-tax sole proprietors without VAT. (Law of Ukraine)

When RRO/PRRO can be omitted

The most common legal case without RRO/PRRO is when payment is received not through a settlement operation, but as a classic bank transfer from account to account using IBAN details. The tax service officially explains that direct fund transfers to the seller's current account, as well as depositing funds through a bank cash desk to such an account, do not require the use of RRO/PRRO. For services, there is an additional separate legal exemption: if settlements are carried out exclusively through remote banking systems and/or fund transfer services, RRO/PRRO are not used. (zak.tax.gov.ua)

There are other exceptions, but they are narrow and special. The law expressly exempts certain banking operations, some sales of products of own production by enterprises through the cash desk with cash receipt and payment orders, and specific operations in places where settlements are not actually conducted — for example, in warehouses or wholesale premises without accepting cash or cards. Separately, the Cabinet of Ministers approved a list of special forms of activity where it is permitted to work without RRO/PRRO, but with settlement books and KURO; this is not a general exception "for small business", but a closed list of specific situations. (Law of Ukraine)

Which payments are considered settlements

A mistake that costs businesses fines is assuming that any cashless payment automatically exempts them from RRO. The law defines a settlement operation broadly: it is the acceptance of cash, payment cards, checks, tokens, and other payment means at the place of sale of goods or services, as well as the execution of relevant documents for cashless payment through a payment instrument. Therefore, paying by card via a website, payment button, internet acquiring, POS-terminal, or through a courier with a terminal is generally a settlement operation. (Law of Ukraine)

Separately, the tax authorities clarified a nuance with QR codes. If the QR code contains only the IBAN account details for a standard bank transfer, an RRO/PRRO is not required. However, if the QR code actually leads to payment by an electronic payment instrument or contains details initiating a card/acquiring payment, an RRO/PRRO is already needed. (if.tax.gov.ua)

What to choose: classic RRO or PRRO

The law allows both formats. A classic RRO is a hardware registrar with registration through the tax office and commissioning through the technical service center (CSO). A PRRO is a software solution registered electronically and operating via a fiscal server. Both options are legal if they are properly registered and used according to the rules. (Law of Ukraine)

For businesses with retail outlets where redundancy during power outages is important, a classic RRO might be more convenient, because the law allows the use of KURO/settlement books or a backup RRO in case of breakdown or power loss — provided the business has not opted out of this mechanism. For a PRRO, the basic rule is different: if the PRRO itself malfunctions, sales are not conducted, and if connection with the server is lost, work continues in offline mode according to special rules. (Law of Ukraine)

There is also a direct legislative restriction: a PRRO cannot be used during wholesale or retail fuel trade. For such businesses, there is no choice — a classic RRO and compliance with separate licensing and industry requirements are necessary. (Law of Ukraine)

Classic RRO registration

A classic RRO can be registered only when the model is included in the State Register of RROs, has not exceeded its service life, and the primary registration period. An application using form No. 1-RRO is submitted to the controlling authority at the main place of registration. If there are no grounds for refusal, the tax office reserves a fiscal number, and after sealing and commissioning through the CSO, it completes the registration and generates a registration certificate. (Law of Ukraine)

Refusal to register a classic RRO can be received, in particular, if the RRO is already registered, the model is absent in the State Register, the scope of application does not match the application, there is no valid agreement or notification of an agreement with the CSO, the object has not been submitted using form 20-OPP or is marked as closed/non-operational, the business is not registered, or data do not match state registers. That is why before registration it is worthwhile to put the premises, their documents, and the object's tax accounting in order. (Law of Ukraine)

PRRO registration

A PRRO is registered electronically using form No. 1-PRRO through the Electronic Cabinet or via telecommunications means. In the application, the business entity itself assigns a local number to the PRRO; it must be unique within this entity and is retained by the PRRO until the registration is canceled. If there are no grounds for refusal, the PRRO receives a fiscal number and is considered registered from the date indicated in the information system of the controlling authority. (Law of Ukraine)

For cashiers to work with a PRRO, a notification in form No. 5-PRRO is submitted regarding qualified or advanced certificates of electronic signatures/seals. An employee can work with a PRRO only after their certificate data is entered into the PRRO Register and provided the certificate is valid. When changing the business name, tax number, name of the business unit, or its address, the PRRO is subject to re-registration, which can only be done after closing the last shift and submitting the final Z-report. (Law of Ukraine)

PRRO registration is denied if there are issues with the electronic document or signature, an identical PRRO with the same local number is already registered, the object has not been submitted via form 20-OPP or is closed/non-operational, and if data about the entity is missing or does not match tax accounting data. (Law of Ukraine)

Business unit, premises, and documents

For RROs and PRROs, it is critically important to correctly register the business unit. The fiscal receipt must display the name of the business unit and its address exactly as they appear in the documents on the right of ownership or use and as submitted to the tax authorities via form 20-OPP. That is, the address in the receipt, in the 20-OPP, in registration applications, and in premises documents must match. (Law of Ukraine)

In practice, a business needs to have at least: a document on the right of ownership or use of the premises/place of activity, a properly submitted 20-OPP, registration documents for the RRO or PRRO, valid QES keys for responsible persons, and for a classic RRO — documents from the CSO on sealing and commissioning. The absence or inconsistency of these documents is a typical cause of problems with registration and audits. (Law of Ukraine)

What the fiscal receipt should look like

A modern receipt is not just an amount and a date. Mandatory details are determined by the Ministry of Finance. The receipt must contain, among other things, the name of the business entity, the name and address of the business unit, the tax number or VAT number, product or service name, price, quantity, form of payment, amount, date and time of the transaction, fiscal number, QR code for document verification, and other mandatory details depending on the transaction type. (Law of Ukraine)

For businesses, this means you cannot work with nominal names like "product", "service", or "item 1" if the document does not make it clear what exactly was sold. For single-tax sole proprietors without VAT, there are separate relaxations regarding the format of the product/service name, but they do not apply to risk categories, including technically complex household goods, medicines, medical devices, jewelry, and excisable products. (Law of Ukraine)

A receipt can be issued in paper and/or electronic form. The tax office separately explains that this means the possibility to provide the buyer with a paper receipt, an electronic receipt, or both — depending on the payment model and technical organization of the sale. For online orders and deliveries, an electronic receipt is a full-fledged settlement document if formed according to the rules. (Law of Ukraine)

Online store, delivery, and cash on delivery

For e-commerce, the main rule is: if you accept card payment through a website, payment service, or internet acquiring, it is a settlement operation and a fiscal receipt is required. If the buyer pays via regular bank transfer by IBAN to the seller's current account, it is a different scenario where an RRO/PRRO might not be applied. The mere fact that a sale occurs via the internet does not cancel the RRO; the payment method is decisive. (zt.tax.gov.ua)

During delivery, it is crucial to understand who exactly accepts the money from the buyer. If post-payment or card payment upon goods delivery is accepted by the carrier as a separate participant in the settlement and then transfers funds to the seller's account, the fiscalization procedure depends on the contractual model, and the settlement document for receiving funds is usually generated by the one accepting these funds from the buyer. However, if your courier or employee takes money or a card from the buyer, the receipt must be generated precisely by the seller. With mixed payments, each separate settlement operation is fiscalized individually. (zt.tax.gov.ua)

Offline mode, breakdowns, and outages

For PRRO, the basic rule is: in the absence of connection with the fiscal server, you can work in offline mode, but standard limits apply — no more than 36 consecutive hours and no more than 168 hours during a calendar month. After restoring the connection, the package of documents must be transmitted to the server within established timeframes, and operations must contain signs of the offline mode. (Law of Ukraine)

During martial law, state of emergency, or force majeure circumstances, the law allows exceeding these time limits for PRRO offline mode. This is a vital exemption for businesses operating under unstable connections. However, it does not cancel the obligation to properly document operations and transmit data after the server's operation is restored. (Law of Ukraine)

For a classic RRO, during malfunction or power outage, a KURO with a settlement book or a backup RRO can be used — for no more than seven working days. However, if the business entity voluntarily waived the use of a KURO/RC for such cases, then sales cannot be conducted during breakdowns or power outages. (Law of Ukraine)

Inventory accounting and product documents

The law requires business entities to maintain records of inventory in the manner prescribed by law and to provide regulatory authorities during inspections with documents confirming the accounting and origin of goods present at the place of sale at the time of the check. For a business, this means that products without supporting documents represent a separate risk, even if you issue receipts correctly. (Law of Ukraine)

There is an exception to this rule for single-tax sole proprietors without VAT, but not for everyone. The relaxation does not cover those selling technically complex household goods, medicines, medical devices, jewelry, and household goods made of precious metals and stones. For these categories, product documents and proper accounting are mandatory. (Law of Ukraine)

Excisable goods: a separate risk level

If a business trades in alcohol, tobacco products, e-cigarette liquids, or other excisable goods, requirements are stricter. The receipt must feature proper product programming, the UKT ZED code in cases stipulated by law, and for alcoholic beverages — details of the excise stamp or electronic stamp where mandatory. It is specifically for excisable products that fines remain the most sensitive even during martial law. (Law of Ukraine)

In addition to RRO rules, trading excisable goods separately depends on a valid license under a special law. Starting from 2025, Law No. 3817-IX is in effect; the tax office expressly states that licenses issued before January 1, 2025, under the old Law No. 481/95-VR remain valid until expiration or termination under the new rules, and the list of grounds for license termination is determined by the new law. Therefore, for such businesses, an RRO mistake is only part of the risk; the other part is licensing. (Law of Ukraine)

Fines in 2026

The main fine for failing to conduct a settlement operation through an RRO/PRRO, processing it for an incomplete amount, or failing to issue a settlement document to the buyer currently stands at 100% of the value of goods, works, or services for the first violation and 150% for each subsequent one. This is the baseline financial risk for most violations in the fiscalization sphere. (Law of Ukraine)

There are separate fines for violating KURO/RC usage rules, failing to store or provide the control tape, and for excisable goods — for conducting operations without programming mode specifying the UKT ZED product subcategory code, name, price, and quantity accounting. Selling unaccounted goods or failing to provide product documents incurs a penalty equal to the value of such goods at retail prices, but not less than ten tax-free minimum incomes of citizens. (Law of Ukraine)

Martial law does not grant universal "immunity" from liability nationwide. The preferential regime with reduced rates of 25% and 50% for certain single-tax sole proprietors without VAT was valid only until July 31, 2025. Currently, the law retains special rules on the non-application of liability for specific non-excise violations in temporarily occupied territories, territories of active hostilities, or possible hostilities — within the limits and periods expressly defined by the law. (Law of Ukraine)

What a business should check before starting or an audit

Before starting work, it's worth going through a brief checklist: determine if you have settlement operations specifically; correctly register the business unit and file 20-OPP; choose a legal RRO or PRRO format; set up correct product and service names; verify receipt details; issue QES for cashiers; configure the process for deliveries and cash on delivery; have product documents and, if needed, licenses; separately check if you fall under special restrictions for excisable products or fuel. Fines arise most frequently at the intersection of these issues. (Law of Ukraine)

PRRO for trading in Torgsoft: list of accounting software features

The "Software RRO (PRRO)" option in Torgsoft is the company's own integrated solution that allows you to fiscalize sales, generate electronic receipts, and interact with the State Tax Service (DPS) servers without using third-party services (such as Checkbox or Vchasno).

Below is a detailed list of PRRO features in Torgsoft: