RRO registered before store opening: Are receipts and zero Z-reports required?

If you have registered a hardware fiscal cash register (RRO, the Ukrainian legal acronym) or its software equivalent (PRRO), but the store has not yet opened and you have not settled payments with customers, you do not need to make fictitious sales. Registering a cash register is not itself a settlement transaction. For a hardware RRO, daily zero Z-reports are not required when no such transactions have taken place.

For a PRRO, separately check whether a shift is open. If the cashier has already opened one, they must close it with a Z-report, even if there were no sales. The cashier must close the shift within 24 hours of opening it. Do not open a PRRO shift before the store opens unless necessary.

When a settlement transaction occurs

Article 2 of Law No. 265/95-VR links a settlement transaction to a customer's payment or a refund to the customer. For an ordinary store, this includes accepting cash for goods, payment by bank card, and refunding money for returned goods.

For example, a customer pays by card for a sweater at the checkout—the store has carried out a settlement transaction. The cashier must process it through a duly registered RRO or PRRO for the full amount and provide the customer with a fiscal receipt in paper or electronic form.

Submitting an application to register a cash register, receiving a fiscal number, and setting up goods and prices do not in themselves mean that the store has accepted payment. Therefore, the registration date does not require an entrepreneur to start selling on that same day.

At the same time, base your actions on actual transactions, not only on the announced opening date. If you have already accepted payment for goods before the grand opening, and it meets the definition of a settlement transaction, comply with the receipt and Z-report requirements.

When a zero Z-report is required

A Z-report is a fiscal report receipt summarizing the cash register's activity for a day or shift. Paragraph 9 of Article 3 of Law No. 265/95-VR requires it to be generated daily if the store has carried out settlement transactions. For a hardware RRO, the applicable procedure also provides for generating this report at the end of the working day or shift.

If a hardware RRO is registered but no settlement transactions have taken place, a daily zero Z-report is not required. This applies both while the store is being prepared and on a day with no settlements after trading has begun.

With a PRRO, registration and opening a shift are separate actions. After registration, the cash register receives a fiscal number. When the cashier opens a shift, the PRRO sends a separate message to the State Tax Service (STS) fiscal server. To close that shift, the cashier generates a Z-report and submits it for registration. Therefore, a shift that has already been opened must be closed even if there were no customers.

Illustrative example: a sale took place only on opening day

An entrepreneur registered a cash register on October 5 and opened the store on October 12. There were no payments or refunds before opening, and no PRRO shift was opened. Daily zero Z-reports are not required for October 5–11.

On October 12, the cashier sold two items for UAH 350 each: 2 × 350 = UAH 700. The cashier processed the payment through the cash register, gave the customer a receipt for UAH 700, and generated a Z-report at the end of the shift. If there were no settlements on October 13, a zero Z-report is not required for a hardware RRO. For a PRRO, the answer depends on the shift: the cashier closes an open shift with a Z-report, while a shift that has not been opened does not need to be opened. No additional sale “for reporting purposes” is needed in either case.

Cash float deposits and withdrawals

When a cashier puts money in the cash register for making change or removes cash, this does not mean that goods have been sold. For cash movements unrelated to a settlement with a customer, the procedures for using RRO and PRRO provide for “service cash deposit” and “service cash withdrawal” transactions.

For example, before the first purchase, the cashier puts UAH 1,000 in the cash register for making change. The cashier records this amount as a service cash deposit, not as a sales receipt. If a customer later pays UAH 250 for goods, the sale amount is UAH 250. The cash float does not increase it to UAH 1,250.

Do not use a service cash withdrawal to substitute for refunding a customer for goods: such a refund is a settlement transaction. If you opened a PRRO shift for a service transaction, close it with a Z-report after finishing work.

What to check before the first customer

The owner or accountant checks the store details and cash register registration. For a hardware RRO, the service and technical preparation is carried out by an authorized service center (ASC). The cashier checks the payment, receipt issuance, and shift-closing procedures.

1. Check the store details in Form No. 20-OPP. A business unit is a specific retail location to which the cash register is linked. Check its name, address, identifier, and actual status in the private section of the Electronic Cabinet. The address must match the premises documents and the cash register registration details.
2. Check that registration is complete. For a hardware RRO, check the registration certificate after submitting Form No. 1-RRO. For a PRRO, check the STS receipt confirming successful registration under Application No. 1-PRRO: it must show the assigned PRRO fiscal number. Keep the submitted documents and received confirmations.
3. Prepare the hardware RRO together with the ASC. Check the service agreement, commissioning, fiscal mode, and seal integrity. Keep the registration certificate and the latest sealing certificate, or copies of them, at the settlement location.
4. Check the PRRO cashier's signature. A qualified electronic signature (QES) is the electronic signature the cashier uses to sign electronic documents. Make sure the certificate is valid and that the STS has entered the details of the relevant signature or seal in the register after Form No. 5-PRRO was submitted.
5. Check goods, prices, and taxes. The cashier must select the correct product name, quantity, price, and tax group. For excisable goods, also check the required special details, including the UKTZED code—the product code under the customs classification.
6. Check receipt settings. Verify the seller, store name and address, tax details, goods, amounts, payment method and form, applicable tax details, date, time, receipt and cash register numbers, QR code, and other details required for your transaction. If the payment terminal is connected or integrated with the cash register, account for the payment-detail requirements.
7. Show the cashier the operating procedure. They must know how to provide a paper or electronic receipt, check the transaction result, and generate a Z-report. After the first actual purchase, check the receipt issued and confirmation that it was fiscalized.

Form No. 20-OPP must be submitted within 10 business days after an object is registered, created, or opened. If its type, name, address, type of right to the object, or status changes, the taxpayer submits Form No. 20-OPP with updated details within 10 business days of the change. Do not put off checking this information until the first payment: it is needed for correct cash register registration and receipt details.

A registered RRO does not replace a license for trading in goods for which one is required. If you plan to sell such excisable goods, obtain the relevant license before trading begins. A PRRO is prohibited from being used for wholesale and retail trade in fuel.

If the opening is postponed or the store changes

If you have only postponed the opening date and the store, its address, and its registration details have not changed, you do not need to cancel the cash register registration because of the delay alone. Before starting work, check its status, documents, and the validity of electronic signatures again.

If the cash register will operate in another store, first submit the required information using Form No. 20-OPP, and then re-register the cash register. For a hardware RRO, submit Form No. 1-RRO marked “Re-registration” and the registration certificate. For a PRRO, submit Form No. 1-PRRO with the corresponding mark. Before re-registering a PRRO, close the last open shift and submit its Z-report.

A change to the name or address of a business unit also requires PRRO re-registration. Other changes to its details may require an application marked as an amendment. Check the STS receipt: it must confirm successful re-registration or amendment. Generate receipts with the new details only after that. Re-registering a PRRO does not change its fiscal number.

If you decide to stop using the cash register altogether, arrange for its registration to be cancelled. For a hardware RRO, the ASC first removes the seals; the entrepreneur submits Form No. 4-RRO and the registration certificate and receives a cancellation certificate. Before cancelling a PRRO, send the fiscal server all copies of settlement documents bearing numbers assigned in offline mode, electronic fiscal report receipts, and messages required under the PRRO procedure. Then submit Form No. 1-PRRO marked “Cancellation of registration.”

Some grounds for cancellation apply regardless of the owner's decision. In particular, reporting a business unit as closed or not in operation is grounds for cancelling a hardware RRO registration and automatically cancelling a PRRO. Therefore, state the object's actual status in Form No. 20-OPP. Cancelling a cash register does not erase previously registered fiscal data or cancel document-retention obligations.

What violations carry penalties

Early cash register registration and the absence of sales are not, by themselves, violations subject to the penalty under paragraph 1 of Article 17 of Law No. 265/95-VR. That provision covers settlements for less than the full amount, failure to process a transaction through the proper fiscal cash register, and failure to issue the relevant settlement document.

The general penalty is 100% of the sale amount involved in the violation for the first violation and 150% for each subsequent violation. The reduced penalties of 25% and 50% provided for certain individual entrepreneurs applied only until July 31, 2025.

Paragraph 10 of Article 17 provides for 30 non-taxable minimum incomes of citizens for failure to submit reports and electronic copies of documents when submission is mandatory. This is not a penalty for failing to produce a zero Z-report on a day when a hardware RRO carried out no settlement transactions.

Paragraph 14 of Section II of the Law provides territorial exemption from liability for violations committed in selling goods or providing services starting October 1, 2023. It covers temporarily occupied territories until the date the occupation ends; active combat zones until the date hostilities end; and possible combat zones until the date the possibility of hostilities ceases. The relevant dates are determined according to the official List of Territories. The exemption does not apply to violations of settlement procedures when selling excisable goods, and it does not cancel the cash register operating requirements themselves.

How to prepare Torgsoft PRRO for the first sale

Torgsoft Software RRO (PRRO) is an additional option with a one-year license. It is activated separately for each workstation where sales are fiscalized. Before starting work, add a QES, submit documents to register the business unit, PRRO, and cashiers, and check the STS receipts.

Next, configure fiscal goods, prices, and tax rates. If mixed receipt printing mode is enabled, before payment the cashier must check the colored square in the “Payment” window: green means the program will process fiscal goods through the fiscal printer, and non-fiscal goods through an ordinary receipt printer. If the square is red, all goods paid for in cash will go to the non-fiscal printer. For cashless payments, the cashier must also check the “Always print a fiscal receipt for cashless payments” setting in the “Settings — Parameters — Receipt” menu: if enabled, fiscal goods are fiscalized regardless of the square's color; if disabled, the result depends on the selected color. For sales that must be fiscalized, check both the goods' fiscal status and the green payment mode. An ordinary goods receipt does not replace a fiscal receipt when the law requires one.

Open the first Torgsoft PRRO shift while connected to the STS fiscal server: during this opening, the program receives data needed for offline operation. If you have already opened a shift during preparation, select “Print Z-report” and check that the shift is closed. If the shift has not yet been opened, you do not need to open it merely because PRRO registration is complete.

Official sources

• Law of Ukraine “On the Use of Settlement Transaction Registrars in Trade, Public Catering and Services” No. 265/95-VR: Article 2; paragraphs 1, 2, 7, 9, 11, and 14 of Article 3; paragraphs 1 and 10 of Article 17; paragraphs 14 and 15 of Section II.
• Procedure for Registration, Maintenance of the Register, and Use of Software RRO (PRRO), approved by Ministry of Finance Order No. 317 dated 23.06.2020: Section II—registration, cashier signatures, and re-registration; Section III—cancellation; paragraphs 2–5 and 9 of Section IV—use, shifts, and service transactions.
• Procedure for Registration and Use of RRO, approved by Ministry of Finance Order No. 547 dated 14.06.2016: Chapters 3 and 4 of Section II—re-registration and cancellation; paragraphs 3–6 of Section III—place of use, documents, Z-reports, and service transactions.
• Procedure for Keeping Records of Tax and Levy Payers, approved by Ministry of Finance Order No. 1588 dated 09.12.2011: paragraphs 8.4–8.6 and 8.8 of Section VIII—Form No. 20-OPP, deadlines, changes, and review of information.
• Regulation on the Form and Content of Settlement Documents and Electronic Settlement Documents, approved by Ministry of Finance Order No. 13 dated 21.01.2016: Section II—Form No. FKCH-1, mandatory fiscal receipt details, and conditions for completing them.

STS guidance on closing a PRRO shift: maximum shift duration—24 hours; procedure for generating a Z-report.