Inventory records means documenting the receipt and disposal of goods and supporting each movement with primary documents. The requirement is set out in the Law on Cash Registers (RRO), and the procedure and form for sole proprietors (FOP) are established by Ministry of Finance Order No. 496.
Key point for 2026: the exemption from inventory accounting applies only to certain single-tax (unified tax) FOPs who are not VAT payers (with exceptions for “high-risk” categories of goods). For unrecorded goods, the financial penalty is 100% of the value at selling prices (but not less than 10 tax-free minimum incomes), and administrative fines for violations of the settlement procedure may be imposed through court.
When selling goods, an entrepreneur must keep records of them. This obligation is defined in the Law on RRO, and the procedure for keeping such records for FOPs is approved by Ministry of Finance Order No. 496.
Since entrepreneurs still have many questions about accounting rules when working with an RRO or pRRO, below are the key points актуальні as of 2026.
What are inventory goods (stock)?
Inventory goods (stock) are the totality of goods that an entrepreneur uses for sale or for providing services. Items that are not intended for sale (for example, raw materials used in production) do not belong to inventory stock.
What is inventory accounting?
Inventory accounting is recording receipts and disposals of goods in the prescribed form/accounting system. Each transaction must be supported by primary documentation.
In simple terms: a FOP must show where the goods came from (receipt) and where they went (sale, write-off, return to supplier, transfer between locations, etc.).
Which FOPs must keep inventory accounting in 2026?
The basic rule is: if a FOP sells goods/provides services and the requirements of the Law on RRO apply to them, they must keep inventory accounting and sell only those goods that are reflected in the accounting records. The law also requires keeping documents that confirm inventory accounting and the origin of goods at the place of sale as of the start of an inspection. This follows directly from the Law on RRO (in particular, the requirements on inventory accounting and the exemptions for certain FOPs).
MUST KEEP INVENTORY RECORDS (in most cases):
- FOPs under the general taxation system.
- FOPs who are VAT payers (including Unified Tax Group 3 with VAT).
- FOPs under any taxation system if they sell “high-risk” categories: technically complex household goods subject to warranty repair (TCHG), medicines, medical devices, jewelry and household goods made of precious metals/stones. For these categories, the “single-tax non-VAT” exemption does not apply.
DO NOT KEEP INVENTORY RECORDS (an exception to the general rule):
- FOPs who pay the unified (single) tax and are not registered as VAT payers, provided that they do not sell TCHG/medicines/medical devices/jewelry and other listed “high-risk” categories.
Important: in the previous version of the “Summary” block there was a logical contradiction — it included single-tax non-VAT FOPs, who are exempt from inventory accounting if they do not trade in “high-risk” goods. This should be corrected in line with the law.
How to keep inventory records correctly
Inventory is accounted for at the place of sale (the business premises/object). RRO or pRRO is used for settlements, while inventory accounting is maintained in the form/register prescribed by Ministry of Finance Order No. 496.
The inventory form records all receipt and disposal transactions, and every entry is backed by primary documents (invoices, acts, internal transfers, stocktaking, etc.).
In practice, the form under Order No. 496 is treated as the basic and expected approach by контролюючі bodies. For business this means a simple rule: if you cannot document the path of the goods — the risk of penalties increases sharply.
.png "Inventory accounting form")
Typical transactions that must be supported by primary documents and reflected in the records:
- receipt of goods from a supplier;
- disposal of goods (sale, write-off, use in business activity);
- internal transfers between warehouses/points of sale;
- return of goods to a supplier;
- stocktaking (inventory count) and documenting discrepancies.
Important! If an entrepreneur sells goods at several points of sale, inventory accounting must be kept separately for each place of sale, and transfers between locations must be documented.
During an inspection, the controlling authority typically asks to provide documents confirming inventory accounting and the origin of goods available at the place of sale. These may include stocktaking documents, receipts, internal transfer documents, etc.
Penalties for missing inventory accounting in 2026 (updated)
For selling goods that are not recorded in the prescribed manner, and/or for failing to provide during an inspection documents confirming inventory accounting at the place of sale, a financial penalty applies in the amount of the value of such goods at selling prices, but not less than 10 tax-free minimum incomes (i.e., not less than 170 UAH if calculated as 10 × 17 UAH).
The statement “penalties are not applied during martial law if the FOP does not sell excisable goods” is not universal and may be misleading for 2026. Law No. 3219-IX restored liability for RRO/pRRO violations from October 1, 2023, and exemptions from liability depend on doing business in territories defined in the established manner (lists of territories of hostilities/occupation) and may have exceptions, including for excisable goods.
Separately, there is administrative liability for violations of the settlement procedure (Article 155-1 of the Code of Administrative Offenses): a fine for persons who carry out settlement transactions is from 2 to 5 tax-free minimum incomes, and for a repeated violation within a year — from 5 to 10 tax-free minimum incomes (applied through the protocol procedure and court review).
Do FOPs have to keep inventory accounting when providing medical services?
In clarifications, the tax authority states that when providing medical services, inventory accounting may not be required as “accounting for goods for sale.” At the same time, if an entrepreneur sells medicines or medical devices, this is already the sale of “high-risk” categories, for which the exemptions do not apply, and inventory accounting becomes mandatory.
Additional important note for 2026: payment terminals (POS) and cashless settlements
Although this article is about inventory accounting, in 2026 the topic is closely linked to accepting payments and using RRO/pRRO. At the end of 2025, the Government postponed mandatory use of payment terminals for Unified Tax Group 1 FOPs — until the end of martial law and for three months after it is canceled (public communications link this to Resolution No. 1768 dated 29.12.2025).
For Unified Tax Groups 2–3 and other categories, the requirements to ensure the possibility of cashless settlements remain relevant under the general rules. In practical terms: set up your process so that card/QR/app payments correctly “land” in your accounting and do not create gaps between sale, fiscalization, and stock balances.
How inventory accounting is implemented in Torgsoft
Torgsoft automates accounting and business processes to reduce manual work and the risk of errors in documents and stock balances. To keep inventory accounting in the program, you need to set up the inventory form — it contains the required fields aligned with legal requirements: primary document details, receipts, disposals, and notes.
- sequential entry number;
- date the information is entered;
- primary document details;
- value/amounts confirmed by primary documents;
- data on receipt and disposal of goods;
- notes.
You can also enable automatic stock calculation: the system helps you see real stock balances, reduce shortages and overstocks, and rely on “primary documents” in your accounting.
2026 focus: many owners manage their business remotely. Automation allows you to quickly check stock balances, stock movements, and the basis (primary documents) even without being physically present at the point of sale — which is critical when an inspection or a document request happens “same day.”
The conclusion is simple: proper inventory accounting is not “bureaucracy” — it is insurance against penalties, disputes with regulators, and internal losses due to chaotic stock management. If you keep records systematically and support transactions with primary documents, the risks of inspections and additional assessments are noticeably lower.
Template “Inventory accounting form” – xls or on Google Drive
Go back to the previous step