Penalties for not using ECR/pECR in 2026

As of March 2026, the following rule applies to entrepreneurs: if a settlement operation is conducted without an RRO or PRRO, not for the full amount, without issuing a proper settlement document, or with a document that does not meet the requirements of form and content, the tax authority may apply financial sanctions under the Law of Ukraine No. 265/95-VR. In 2026, it is necessary to focus on the general liability regime, without relying on transitional reduced fines. (Legislation of Ukraine)

Law No. 265 obliges the business entity to conduct settlement operations for the full purchase amount through a registered RRO, a registered software RRO, or in cases provided by law, using registered settlement books, and also to provide the buyer with a settlement document of the established form and content for the full operation amount. Most of the fines in the RRO area are built around these obligations. (Legislation of Ukraine)

What financial sanctions are in effect in 2026

The main sanction is determined by paragraph 1 of Article 17 of Law No. 265. For the first detected violation, a fine of 100% of the value of goods, works, or services sold with a violation is applied. For each subsequent violation, a fine of 150% of the value of goods, works, or services sold with a violation is applied. These specific rates are the basic ones for 2026. (Legislation of Ukraine)

For an entrepreneur, this means that the risk arises not only when cash register equipment is not used at all, but also when the sale is fiscalized incorrectly. If the operation is not conducted for the full amount or a proper receipt is not issued to the buyer, the consequence for the business can be the same as in the case of an actual sale without an RRO. (Legislation of Ukraine)

What exactly you can be fined for

The most common grounds for applying a fine are conducting settlements without a registered RRO or PRRO, conducting settlements not for the full value of the goods or services, not issuing a settlement document to the buyer, as well as issuing a document that does not meet the established form and content. For the tax authority, not only the very fact of the receipt's existence is important, but also whether it confirms the operation in the form required by law. (Legislation of Ukraine)

When it comes to an inspection, the tax authority usually looks at several things at once: whether there is a registered RRO or PRRO, whether the amount is entered correctly, whether a receipt was issued to the buyer, whether the receipt meets the mandatory details, and whether the seller complies with the requirements regarding the payment acceptance method. Therefore, the penalty risk often arises not from one major failure, but from a combination of minor operational errors. (Legislation of Ukraine)

Updated requirements for fiscal receipts in 2026

The form and content of settlement documents are determined by the Regulation approved by the Ministry of Finance Order No. 13. Changes to this Regulation were introduced by the Ministry of Finance Order No. 601, and the deadline for their practical application was postponed by the Ministry of Finance Order No. 674. As a result, the updated requirements for receipts apply from March 1, 2025, and continue to be in effect in 2026. (Legislation of Ukraine)

The key risk is that under Regulation No. 13, in the absence of at least one of the mandatory details in the document or non-compliance with its scope of application, such a document will not be accepted as a settlement document. This does not mean that any technical error will automatically lead to a fine, but the absence of a mandatory detail does create a risk for the business that the tax authority will not recognize the receipt as a proper settlement document. (Legislation of Ukraine)

Therefore, in 2026, the correctness of the details in the receipt has the same practical significance as the very fact of fiscalizing the operation. If the receipt is generated with a violation of mandatory requirements, the controlling body may evaluate the situation as conducting a settlement operation in violation of Law No. 265, and then apply a fine under Article 17 of this Law. (Legislation of Ukraine)

Excisable goods and increased attention to details

For sellers of excisable goods, the requirements for a receipt are traditionally stricter, since the settlement document must contain the details that allow identifying the goods and confirming compliance with special rules for their sale. That is why for alcohol, tobacco products, and other excisable items, incorrect configuration of cash register equipment or PRRO poses an increased risk. (Legislation of Ukraine)

In practice, this means that it is not enough for an entrepreneur to simply "print a receipt". It is necessary to make sure that the software or hardware RRO generates a receipt in exactly the structure required by the current Regulation No. 13, taking into account recent changes. (Legislation of Ukraine)

Administrative liability that may be applied in parallel

In addition to financial sanctions under Law No. 265, administrative liability also operates in the area of settlements. Article 155-1 of the Code of Ukraine on Administrative Offenses (CUAO) provides for fines for violating the procedure for conducting settlements in the sphere of trade, catering, and services. Such fines can be imposed on individuals who directly conduct settlement operations, as well as on officials, and for a repeated violation, the liability increases. (Legislation of Ukraine)

Separately, Article 163-15 of the CUAO establishes administrative liability for violating the procedure for conducting cash settlements, exceeding the limits for cash settlements, as well as for non-compliance with the requirements for ensuring the possibility of settlements using electronic payment methods. For the first violation, the fine is from 100 to 200 tax-free minimum incomes of citizens, and for a repeated one during the year — from 500 to 1000 tax-free minimums. (Legislation of Ukraine)

For an entrepreneur, this is important from a practical point of view: different types of liability can arise simultaneously for the same episode. For example, for a business — a financial sanction under Law No. 265, and for the responsible person — an administrative fine under the CUAO, if there is a separate structure of an offense for this. (Legislation of Ukraine)

Cash limits to consider in 2026

NBU Regulation No. 148 maintains the general limits of cash settlements during one day. Between business entities, cash settlements up to 10,000 UAH inclusive are allowed, and between a business entity and an individual — up to 50,000 UAH inclusive. Payments exceeding these limits must be made in non-cash form. (Legislation of Ukraine)

These limits must be considered separately from the RRO rules. Even if the receipt is generated correctly, exceeding the permissible cash amount in itself can create a risk of administrative liability. (Legislation of Ukraine)

POS-terminal: what is in effect in 2026

Cabinet of Ministers Resolution No. 894 established phased deadlines by which merchants must ensure the possibility of non-cash settlements. For settlements with a population of over 25 thousand people, this obligation arose on January 1, 2023, for settlements with a population from 5 to 25 thousand people — on January 1, 2024, and for settlements with a population of less than 5 thousand people — on January 1, 2025. (Legislation of Ukraine)

At the same time, for single tax payers of the first group, vending machine trade, mobile and portable trade, as well as the sale of self-grown or fattened products, after the changes introduced by CMU Resolution No. 1768 dated December 29, 2025, the obligation to ensure the possibility of non-cash settlements is postponed until three months after the termination or cancellation of martial law. That is, as of March 2026, the rule on a mandatory start specifically from January 1, 2026, does not apply to these categories. (Legislation of Ukraine)

In the territories of communities located in the area of hostilities or temporary occupation, as well as within three months after the termination of such circumstances, the requirements of Resolution No. 894 also do not apply within the limits defined by this resolution. (Legislation of Ukraine)

How an entrepreneur can reduce the risk of fines

The safest approach in 2026 is to check not only the fact of having an RRO or PRRO, but the entire chain of conducting a sale. It is necessary that the cash register solution is registered properly, fiscalizes each operation for the full amount, generates a receipt with all mandatory details, works correctly with returns, discounts, mixed payment methods, and specific product groups. (Legislation of Ukraine)

Special attention should be paid to software updates. If a software RRO is used, it must be updated in a timely manner after changes in regulatory requirements. If a hardware RRO is used, it is necessary to regularly check the settings in the service center and train personnel to work according to the current rules. Formally, the business entity itself bears responsibility before the state, not the supplier of the program or equipment. (Legislation of Ukraine)

Where the business works with excisable goods, several sales channels, delivery, prepayments, cash on delivery, or complex return schemes, before launching a new settlement scenario, it is worth checking exactly how it should be reflected in the receipt. In complex cases, it is advisable to get an official clarification from the State Tax Service or an individual tax consultation specifically for your operating model. (Legislation of Ukraine)

Regulatory framework

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