A Ukrainian individual entrepreneur (FOP) determines whether they need a cash register (RRO) or a software cash register (PRRO) based on how they accept payments, their tax regime, product range, and eligibility for a legal exemption. As a general rule, accepting cash or card payments for goods, including through online acquiring, requires a fiscal receipt. Different rules apply to first-group single-tax payers, direct bank transfers from account to account, and certain types of activity.
Before buying a cash register, list every payment method you accept and check whether you qualify for an exception. If fiscalization is required, choose a hardware RRO or a PRRO, register it, configure products, taxes, and cashiers, and test sales and refund receipts. Plan ahead for power outages: you may continue processing transactions only under the conditions set by law and within the technical capabilities of your solution.

- What are an RRO and a PRRO?
- RROs and the law: who can operate without a fiscal cash register?
- How your product range affects the cash register and inventory records
- What to choose: a hardware RRO or a PRRO
- What you need to register an RRO or PRRO
- Cost of an RRO or PRRO: what to include in your budget
- Opening and closing a cash register shift
- Using an RRO without power or internet
- RRO and PRRO repair and maintenance
- Issuing receipts: what to configure and check
- Using a bank terminal with an RRO
- Fiscal receipts and cash register shifts with Torgsoft PRRO
- Penalties for breaking RRO rules
- Cash register launch and daily control checklist
- Official sources for applying the rules
What are an RRO and a PRRO?
A hardware RRO registers transactions and stores fiscal data in its own fiscal memory. A cash register can operate as a standalone device, while a fiscal printer is generally used with cash register software. RRO users are responsible for sending electronic copies of receipts and fiscal report receipts to the tax authority.
A PRRO runs on the entrepreneur’s device and performs fiscal functions through the server of the State Tax Service of Ukraine (DPS). When working online, the server registers documents and assigns them fiscal numbers. To work offline, a PRRO uses a range of numbers obtained in advance. The definitions and main obligations are set out in Articles 2–3 of Law No. 265/95-VR.
Inventory management, customer databases, analytics, and data exchange with a bank terminal depend on the specific software and enabled features. When choosing a solution, ask the provider to demonstrate a complete sale of one of your products, from scanning it to the customer receiving a fiscal receipt.
RROs and the law: who can operate without a fiscal cash register?
Check each payment method
How the customer pays is an important factor in determining whether you must use an RRO or PRRO. The term “cashless payment” in a bank statement covers different transactions, including card payments that fall under Law No. 265/95-VR.
| How the customer pays | What the entrepreneur should consider |
|---|---|
| Hands cash to the seller | This is a settlement transaction. Use an RRO or PRRO unless your business qualifies for a legal exception. |
| Pays by card through an in-store terminal | A card payment is a settlement transaction. Unless an exemption applies, the customer must receive a fiscal receipt. |
| Pays for goods by card on a website through acquiring | Apply the fiscalization rules for settlement transactions. The subsequent transfer of proceeds to the seller’s account does not change how the customer paid. |
| Transfers funds directly from their bank account to the seller’s business account using the seller’s full bank details | With this kind of direct transfer, the seller does not process a settlement transaction through an RRO or PRRO. Keep the invoice, bank statement, and sales documents. |
| Pays for a service through a remote banking system or money transfer service | Check that the conditions of Clause 14, Article 9 of Law No. 265/95-VR are met: payments for services must be made exclusively through such systems and/or services. |
Practical recommendation: ask your bank or payment provider to describe the mechanism for every payment method you use in writing. Compare that description with your contract and bank statement. A payment link, a transfer to a card number, and a direct transfer using account details each require separate consideration because the button label “Pay” does not reveal how the payment is processed. The legal basis is the definition of a settlement transaction in Article 2 and the obligations in Article 3 of Law No. 265/95-VR.
First-group single-tax payers
First-group single-tax payers do not use an RRO or PRRO under Clause 296.10 of the Tax Code of Ukraine. The entrepreneur must continue to meet the requirements for their tax group. Before changing groups or expanding the business, check whether the exemption will still apply.
For FOPs in the second and third groups, single-tax-payer status alone does not provide a general exemption from fiscalization. Entrepreneurs on the general tax system must also check their actual payment methods and any applicable special exemptions.
Exception for payments for services
Clause 14, Article 9 of Law No. 265/95-VR allows payments for services to be accepted without an RRO, PRRO, or settlement book if they are made exclusively through remote banking systems and/or money transfer services. This clause concerns payments for services. For sales of goods, check the general rules and any other applicable grounds for exemption.
Practical recommendation: if you rely on this exemption, document the permitted payment methods in your service terms and staff instructions. Accepting cash for services would breach the exclusivity condition. If you also sell goods, define separately how payments for those goods are accepted and recorded.
A shop in a village or settlement: when settlement books may be used
A single-tax FOP that sells non-excisable goods at retail in a village or settlement may, subject to the conditions of Item 1 of the list approved by Resolution No. 1336 of the Cabinet of Ministers of Ukraine, operate using a settlement book (RK) and a settlement transaction record book (KORO). The entrepreneur registers these books and issues customers settlement receipts.
The annual limit for settlement transactions under this item is 167 times the minimum wage established by law on January 1 of the tax year, per sales outlet. Once the limit is exceeded, use of an RRO or PRRO becomes mandatory. To monitor this, calculate your own limit using the formula and track transaction volume separately for each store.
Item 1 does not apply if any of the following circumstances apply:
- the same commercial premises also sell excisable goods;
- the FOP conducts distance selling, including online sales;
- the village, settlement, or city council has decided that an RRO or PRRO must be used for this type of business in the relevant area.
In addition, Item 2-1 of Resolution No. 1336 excludes business entities that sell excisable goods at retail from the resolution’s scope. Before choosing an RK and KORO, check your product range, all sales channels, and any decision by the local council. If you rely on another item in the list, apply its specific conditions and limit: the formula based on 167 minimum wages is set for Item 1.
The procedure for registering and maintaining RKs and KOROs is set out in Order No. 547 of the Ministry of Finance of Ukraine. The cashier first fills in the receipt stub, then the detachable part of the receipt, and gives it to the customer no later than the end of the transaction; the responsible person makes the required KORO entries each day. If you use an RK and do not submit the relevant information electronically to the DPS in the manner provided by law, file reports related to its use by the 15th day of the month following the reporting month.
This obligation is established by Clause 7, Article 3 of Law No. 265/95-VR; Report Form No. ZVR-1 and its submission procedure are approved by Order No. 13 of the Ministry of Finance of Ukraine.
How your product range affects the cash register and inventory records
Before configuring the cash register, list your product categories. For excisable goods, the law requires programming the product name, price, quantity, and code of the product subcategory under the Ukrainian Classification of Goods for Foreign Economic Activity (UKT ZED). For alcoholic beverages, include excise stamp details where required by law. Use of a PRRO is prohibited for wholesale and retail trade in fuel—this is expressly stated in Clause 1, Article 3 of Law No. 265/95-VR.
Separately, determine whether you must keep inventory records under Order No. 496 of the Ministry of Finance of Ukraine. It applies to FOPs covered by the obligation in Clause 12, Article 3 of Law No. 265/95-VR. Under this provision, the obligation covers, among others, entrepreneurs on the general tax system and single-tax payers registered as value-added tax (VAT) payers.
Single-tax FOPs who are not registered VAT payers are exempt from these requirements, except for entrepreneurs who sell:
- technically complex household goods subject to warranty repair;
- medicinal products and medical devices;
- jewelry and household goods made of precious metals, precious stones, organogenic precious stones, and semi-precious stones.
If you are required to keep these records, include all inventory held for sale and organize records for each sales location. If the obligation arises because you sell a particular category of goods, include the rest of your product range as well. If you already have goods in stock when the obligation begins, prepare an inventory of the remaining items, listing their names, quantities, units of measurement, and self-determined value, then make it the first entry in the Inventory Record Form.
No such entry is needed if there is no stock. Record new deliveries based on primary documents before selling the goods. Also record documented disposals: internal transfers, returns to suppliers, losses, destruction, use for your own needs, and sales paid by cashless means without an RRO or PRRO in cases permitted by law. Sales through an RRO or PRRO are not entered in the disposal column.
A primary document must make it possible to identify the supplier and recipient, transaction date, product name, quantity, and value. There is an exception for documents concerning destruction, loss, or use of goods for your own needs: supplier and recipient details are omitted, and the value is stated at the purchase price supported by the records. Document internal transfers between your own stores as well.
Keep the Inventory Record Form and primary documents at the sales location until the last unit of goods covered by the relevant document has been disposed of. During an inspection, the entrepreneur or employee who actually sells goods or processes payments must provide these documents to tax officials. If the original primary documents are not at the shop, Clause 11, Section II of Procedure No.
496 allows you to provide copies and, if required, show the originals before the inspection ends. The electronic Inventory Record Form must be presented in a format suitable for viewing and/or copying. Exemption from special inventory records does not remove the requirement to substantiate tax accounting figures with documents under Article 44 of the Tax Code of Ukraine.
What to choose: a hardware RRO or a PRRO
Both options can help meet fiscalization requirements. Choose based on compatibility with your product range, cash register software, equipment, and outage procedures.
| Criterion | Hardware RRO | PRRO |
|---|---|---|
| How it works | A specialized device with fiscal memory. The model and modification must match the State Register of RROs and the intended area of use. | A software solution on the entrepreneur’s device that registers documents through the DPS fiscal server. |
| Registration | Application, number reservation, commissioning, personalization, sealing, and a registration certificate. | Electronic application, assignment of a fiscal number, and submission of data for signature or seal certificates. |
| Maintenance | Contract with a technical service provider (TSP), maintenance, and repairs under the established procedure. | Support for the software and device, updates, and monitoring of electronic signatures and data exchange with the DPS. |
| Receipt for the customer | Paper and/or electronic, depending on the device’s technical capabilities and legal requirements. | Electronic and/or paper, depending on the software’s capabilities and configured delivery method. |
| Working without a connection | Check offline operation, data storage, and blocking rules in the documentation for the specific model. | Requires offline-mode support, an obtained number range, and compliance with applicable conditions. |
| Fuel trade | A suitable specialized solution is required. | Use is prohibited. |
Practical recommendation: before paying, test three transactions: a cash sale, a card sale, and a refund. Check whether the employee can see the fiscalization result, whether taxes are transmitted correctly, and how they can retrieve a receipt copy after a printing error.
What you need to register an RRO or PRRO
Prepare the sales location
Check that the DPS has received the notice of business premises on Form No. 20-OPP and that the location has the correct status. The location’s name and address must match the documents authorizing its use, the cash register registration details, and the receipt information. An unreported, closed, or unused location is grounds for refusing registration.
Hardware RRO
- Choose a model and modification from the State Register of RROs, and check its area of use, eligibility for initial registration, and service life.
- Sign a contract with a TSP. Agree on commissioning and how to report a malfunction.
- Submit an application using Form No. 1-RRO. It may be submitted electronically.
- After the fiscal number is reserved, arrange personalization, sealing, and activation of the device in fiscal mode through the TSP.
- Receive the registration certificate and check all details before starting work. Keep the registration certificate and the latest RRO sealing certificate, or copies of them, at the place where transactions are conducted.
Under Chapter 2, Section II of the Procedure approved by Order No. 547, a decision on whether registration is possible, where there are no grounds for refusal, is made no later than two working days from the date the application is received. Work following number reservation has a specified three-working-day deadline, and completion of registration depends on receipt of the required documents from the TSP. Plan your launch after the entire procedure is complete.
Software PRRO and cashiers
- Choose software and a device that the entrepreneur owns, lawfully possesses, or lawfully uses.
- Prepare an electronic signature. The law permits qualified and advanced electronic signatures and/or seals under specified conditions; ask the software provider whether your specific key is compatible with the software.
- Submit an electronic application using Form No. 1-PRRO, specifying the business premises, the local cash register number, and the selected procedure for loss of connection.
- Receive a receipt confirming the application’s processing and the fiscal number.
- Submit a notice using Form No. 5-PRRO for the public key certificates to be used with the PRRO.
- Check that the certificates are valid and that an authorized person can open a shift.
The result of processing a PRRO application is sent on the day it is received if it arrives before 16:00 on a working operating day; otherwise, it is sent no later than the next working day. Grounds for refusal, cashier procedures, and key protection are set out in Sections II and IV of the Procedure approved by Order No. 317 of the Ministry of Finance of Ukraine.
Practical recommendation: assign someone to monitor key expiry dates, cashier changes, and updates to registration details. Store keys and passwords so only authorized people can access them. Before moving a cash register or changing its details, check whether re-registration is required. If you switch to a PRRO and discontinue a hardware RRO whose service life has not ended, cancel its registration under Procedure No. 547 and submit the reporting documents required by law. Simply activating a PRRO does not cancel the hardware RRO registration.
Cost of an RRO or PRRO: what to include in your budget
Compare costs for the same number of cash registers and the same period of use. For a hardware RRO, include the purchase or rental of the device, TSP services, repairs, software modifications, connectivity, and consumables. For a PRRO, include the device, a license or subscription for the chosen solution, integrations, support, electronic signatures, delivery of electronic receipts, a printer if needed, and backup power.
The DPS provides a free PRRO software solution under Article 2 of Law No. 265/95-VR. Assess equipment and operating costs separately. Ask commercial providers exactly what they charge for: a cash register, workstation, period of use, notifications, or extra features.
For a hardware RRO, check the service life of the specific device and the terms for its continued use. Article 12 of Law No. 265/95-VR ties the use of registered models to their service life and provides that the period between initial registration and removal from the State Register cannot be less than seven years. Consider this when evaluating the remaining service life of a used device.
Opening and closing a cash register shift
Before the first transaction, the cashier checks the equipment, access to the cash register, their PRRO signature, and the cash on hand. Opening a PRRO shift must include creation and registration of the relevant notification. Only one shift can be open on a PRRO at a time. Automatic opening depends on the software’s capabilities and settings.
Before the first settlement transaction following a fiscal report receipt (Z-report), the cashier records cash held at the place of settlement, including opening change, using the Ukrainian interface command «службове внесення» (“service deposit”). Record additional cash deposits not related to a customer payment with «службове внесення» (“service deposit”) as well; record cash withdrawals unrelated to a settlement transaction with «службова видача» (“service withdrawal”). Use the designated settlement transaction to refund a customer.
For a refund exceeding UAH 100 through a hardware RRO, the cashier or financially responsible person prepares a refund disbursement report that includes the buyer’s identity document details, information about the goods, refund amount, and the number, date, and time of the purchase receipt. When cancelling an amount incorrectly processed through a hardware RRO or a wrongly selected payment method, prepare a report with the error details and receipt information as well.
Keep these reports for three years under Clause 8, Section III of Procedure No. 547. For a refund exceeding UAH 100 using an RK, prepare a report under Clause 4, Chapter 2, Section III of the Procedure for registering and maintaining RKs and KOROs.
On any day when settlement transactions take place, create a fiscal report receipt—a Z-report. To close a PRRO shift, send it to the fiscal server for registration; offline operation has a separate procedure for creating and later transmitting documents. The main requirements are set out in Article 3 of Law No. 265/95-VR and Sections IV–V of Procedure No. 317.
Using an RRO without power or internet
Hardware RRO: set a backup procedure
Loss of internet and power outages create different conditions for a hardware RRO. Whether it can register transactions without a connection depends on the device, its data storage, and any blocking features. Check these conditions in the documentation and with the TSP, then include them in the cashier instructions.
For the period when an RRO is broken and being repaired, or during a temporary power outage lasting no more than seven working days, Article 5 of Law No. 265/95-VR provides for the use of registered KOROs and RKs or a properly registered backup RRO.
The entrepreneur may formally decide to stop settlement transactions until a backup RRO is connected or power is restored, and notify the authorities of this when registering. Under this procedure, there is no requirement to register or keep a KORO and RK. The cashier must stop processing payments if the relevant circumstances arise.
If you used an RK, after the repaired or backup RRO is installed, or power is restored, enter in the RRO the transaction amounts from the period of RK use, separately for the applicable tax rates. If the RRO’s operational memory has been erased, also restore the amounts processed before the breakdown or outage from the control tape. Then generate a Z-report and, if necessary, record the actual cash at the place of settlement using «службове внесення» (“service deposit”). The detailed procedure is set out in Clause 10, Section III of the Procedure for using RROs No. 547.
PRRO: check offline mode and document retention
The general offline operating limits for a PRRO are up to 36 continuous hours and up to 168 hours during a calendar month. At the same time, Clause 13, Section II, “Final Provisions,” of Law No. 265/95-VR permits those limits to be exceeded while martial law or a state of emergency is in effect, or during force majeure circumstances. The technical capabilities and settings of the specific PRRO also apply.
Offline operation requires a range of fiscal numbers obtained from the DPS. Under Clause 10, Section V of Procedure No. 317, offline time also includes the interval between the end of one offline session and the start of the next if the fiscal server registered no online settlement document from that PRRO during that interval. Take this into account when monitoring your software’s time limits. If the entrepreneur has chosen not to use offline mode, transactions through that PRRO resume once the connection is restored, or a properly registered backup RRO can be used. A device without power needs backup power for the software to operate.
Once the connection is restored, ensure that the PRRO creates a Form No. 4-PRRO notification that offline mode has ended and, within an hour, sends the fiscal server a package containing the notification that offline mode started, accumulated receipts and fiscal report receipts, and the notification that offline mode ended. Copies of settlement documents must be sent before the electronic fiscal report or fiscal report receipt for the relevant day is transmitted. Keep documents in the PRRO until the fiscal server confirms delivery. Practical recommendation: check the exchange result and look for unsent documents before reinstalling the software, replacing the device, or clearing its data.
RRO and PRRO repair and maintenance
If a hardware RRO malfunctions or its security seals are damaged, notify the TSP on the working day the problem is discovered, then notify the supervisory authority within two working days after that day. Use written notice or electronic communication and keep proof. The TSP must restore the RRO to working order within seven working days. If it has not completed warranty repairs by the seventh working day counted from the date it accepted the RRO for repair, it must put into service a backup RRO properly registered to the entrepreneur.
These obligations are established by Article 14 of Law No. 265/95-VR. Have repairs and work on the device performed through a TSP under Clauses 14 and 16, Article 3 of Law No. 265/95-VR.
A PRRO malfunction also requires notification: on the day it is discovered, submit Form No. 2-PRRO to the supervisory authority and notify the manufacturer and/or TSP, if applicable. Stop processing payments on that PRRO while it is malfunctioning. Once it has been repaired, submit an application marked «Відновлення роботи» (“Restore operation”); if no application is received within a month, the PRRO registration is cancelled under Clause 12, Section II of Procedure No. 317.
Practical recommendation: if an error occurs, save its message, document number, time, and payment result. First determine whether the server has already registered the receipt and whether the bank processed the payment. This will help you choose the right step to restore the transaction and avoid charging the customer twice.
Issuing receipts: what to configure and check
The forms and details of settlement documents are prescribed by Order No. 13 of the Ministry of Finance of Ukraine, dated January 21, 2016. Check the current sales receipt form and the separate refund receipt form.
Before launch, check that the receipt includes the following details, where applicable:
- the entrepreneur’s name, the name and address of the business location, and tax details;
- product names, quantity and price where required by the form, and item totals;
- the payment method and means, applicable amounts, and transaction currency;
- the total amount, rounding, and amount due where applicable, and change for cash payments;
- the fiscal numbers of the receipt and cash register, date and time, a two-dimensional code for locating the receipt—a QR code—and any other details required for that document type;
- for a PRRO, an online or offline mode indicator and the control number for an offline document;
- VAT details for a VAT payer, excise tax, and product codes where required;
- card transaction details required for a terminal connected or combined with an RRO or PRRO.
A single-tax FOP that is not a VAT payer may use a simplified product name permitted by law, provided it reflects the product’s consumer characteristics and clearly identifies its product group under the State Classifier of Products and Services DK 016:2010. This option has exceptions for excisable goods, technically complex household goods subject to warranty repair, medicinal products, medical devices, and certain jewelry and household goods made of precious materials specified by law. In practice, use names that are specific enough for the cashier and customer to identify the item sold.
If a detail required for a particular transaction is missing, the document may not be accepted as a settlement document. However, Clause 3, Section I of Regulation No. 13 expressly states that errors or inaccuracies in a product name that do not distort information about the transaction are not grounds for treating the document as a non-settlement document.
The customer must receive a paper and/or electronic settlement document. An electronic receipt may be sent to a phone number or email address provided by the customer, or made available by allowing the customer to scan a QR code that identifies it. The cashier registers a sale through the RRO at the same time as the settlement transaction, under Clause 5, Section III of Procedure No. 547.
A PRRO also creates an electronic settlement document at the time of the transaction under Article 2 of Law No. 265/95-VR. The document must be issued to the customer or created electronically no later than when the goods are handed over, as provided by Part 11, Article 8 of the Law of Ukraine “On Consumer Protection”.
Practical recommendation: offer a paper receipt or access via QR code to customers who do not provide contact details. If you collect a phone number or email address to deliver a receipt, specify this purpose for processing the data. For any later marketing use of contact details, ensure you have a proper legal basis under Articles 6 and 11 of the Law of Ukraine “On Personal Data Protection”.
Using a bank terminal with an RRO
A bank terminal processes the payment, while an RRO or PRRO registers the settlement transaction. Unless a legal exemption applies, the entrepreneur must complete both steps and issue a fiscal receipt. The terminal slip confirms the card payment and serves its own purpose.
Practical recommendation: before choosing equipment, separately check whether you must give customers the option to pay cashlessly under the requirements applicable to your business and place of trade. With an integrated terminal, check that the amount and payment result are transferred automatically. With a separate terminal, the cashier checks the amount, waits for a successful result, and records the corresponding payment in the cash register software. If there is a malfunction, the cashier checks the bank transaction status before accepting the payment again.
Lines 12–17 of the fiscal receipt, which show acquirer details, payment device information, and card transaction data, are completed when a terminal connected or combined with an RRO or PRRO is used. This condition is set out in Clause 4, Section II of Regulation No. 13. Check how the equipment actually interacts and how data is transmitted before use.
Illustrative example. A customer pays UAH 1,200 for a purchase: UAH 400 in cash and UAH 800 by card. The cashier records the full UAH 1,200 sale and correctly shows both payment amounts. At the end of the shift, the cashier reconciles UAH 400 against cash movements and UAH 800 against card transactions, taking into account other sales, refunds, and service transactions for the day.
Fiscal receipts and cash register shifts with Torgsoft PRRO
Torgsoft’s “Software RRO” option generates receipts in the accounting software and sends them to the DPS. It works with the Start, Ultra, and Terminal licenses. The entrepreneur purchases a paid annual license for the option for each workstation (cash register) where fiscalization takes place. Torgsoft supports fiscalization through its own PRRO option or a compatible hardware fiscal printer; third-party PRROs are not supported. You can submit documents about business premises, the PRRO, and cashiers through the software; this requires configuring the enterprise and the entrepreneur’s qualified electronic signature (QES).
To submit applications, the key must support data encryption, as explained in the official registration guide. Before launch, check the acceptance receipts, fiscal number, and readiness of the cash register.
For daily sales, configure product fiscalization status, taxes, cashiers, printing, and refunds.
- In the standard setup, the cashier uses their own QES.
- If both the “Connect software RRO” and “Link each product sale to a salesperson” options are active and the “For each product” mode is selected, the software signs all fiscal receipts with the PRRO’s shared key and does not use employees’ personal keys; check the type of shared key before enabling this mode.
- Do not give another cashier your personal signature key as an employee or entrepreneur.
- Clause 7, Section II of Procedure No.
- 317 allows use of the electronic signature of the person conducting the transaction or the entrepreneur’s electronic seal; access to the seal key must comply with the restrictions in Clause 2, Section IV of the Procedure.
- Until the provider confirms support for an electronic seal in this mode, configure cashier selection before work so each employee signs receipts with their own QES.
- Automatic terminal data transfer requires the “Bank Terminal Integration” option.
- Sending receipts by email, Viber, or short message service (SMS) requires the “Mass Customer Messaging” option, a template, and a configured delivery service.
- For a smartphone, use the mobile app with a separately configured PRRO; simultaneous operation of the same PRRO in the desktop software and app is not supported.
When offline support is configured, Torgsoft stores documents locally and sends them once the connection is restored. The documented technical limits are 36 hours per continuous session and 168 hours per month; reaching the time or number range limit blocks operation until the connection is restored. Opening a shift for the first time requires internet access, so before an outage check that the shift has opened successfully and the necessary data has been received. After the connection is restored, check that the server has accepted the documents. For details, see the Torgsoft PRRO offline guide and the cashier guide to sales and cash register shifts.
Penalties for breaking RRO rules
For processing a transaction for less than the full amount, failing to process it through the required fiscal RRO or PRRO, or failing to issue the relevant settlement document, Clause 1, Article 17 of Law No. 265/95-VR provides for a financial penalty of:
- 100% of the sale amount processed in violation—for a first violation;
- 150% of the sale amount processed in violation—for each subsequent violation.
Clause 14, Section II, “Final Provisions,” of this Law provides a territorial exemption from liability for violations when selling goods or providing services in temporarily occupied territories and areas of active or possible hostilities. It applies until the relevant date on which occupation or hostilities end, or the possibility of hostilities ceases, according to the official list. The exemption does not apply to violations of settlement procedures when selling excisable goods.
To assess this exemption, compare the sales location, date of the violation, territory category, and dates in the official list. The fact that martial law is in effect does not create a general exemption from liability for all transactions.
For entrepreneurs required to keep inventory records, Article 20 of the Law provides a separate penalty for selling unrecorded goods and/or failing to provide documents during an inspection: the value of the relevant goods at their selling price, but not less than ten non-taxable minimum incomes. This provision’s scope takes account of the statutory exceptions for single-tax FOPs who are not VAT payers.
Cash register launch and daily control checklist
- Describe your payments. List cash, terminal payments, website payments, direct transfers, and payments on delivery. For each scenario, identify who receives the funds, the basis for fiscalization or exemption, and how the customer receives a document.
- Check your group and products. Record your tax status, VAT status, excisable goods, and any product range that affects inventory records and receipt details.
- Compare solutions. Get a cost breakdown for the number of cash registers you need and check equipment compatibility and the transactions demonstrated by the provider.
- Complete registration. Check the business location, fiscal number, cashiers, certificates, and application processing results.
- Check settings. Review sales and refund receipts, card and split payments, and terminal data transmission.
- Prepare a backup procedure. Provide power and connectivity, check offline numbers or registered RKs and KOROs, and define when transactions must stop.
- Train cashiers. Practice opening a shift, making a service deposit, processing a sale, refunding a purchase, correcting a payment error, reprinting a copy, and closing a shift.
- Reconcile totals. At the end of work, check cash, card transactions, refunds, the Z-report, and any unsent documents.
- Keep documents. Organize an accessible archive of registration documents, receipts, reports, and primary product documents, and check that they can be opened.
Law No. 265/95-VR requires hardware RRO control tapes to be kept for three years; used KOROs and RKs must be kept for three years after they are closed. Keep offline PRRO documents until they have been transmitted and delivery confirmed. For tax and other documents subject to DPS oversight, FOPs generally must keep records for at least 1,095 days. For documents used to prepare tax returns, the period starts on the date the return is filed; if it is not filed, the period starts on its filing deadline.
For documents relating to compliance with other legislation overseen by the DPS, the period starts on the date of the relevant business transaction; for permits, it starts when the permit expires. These rules are established by Clause 44.3, Article 44 of the Tax Code of Ukraine. Account for statutory extensions where applicable, and keep documents related to an inspection or appeal until those procedures end and for at least the applicable minimum period.
Official sources for applying the rules
- Law of Ukraine “On the Use of Cash Register Equipment in Trade, Catering, and Services” No. 265/95-VR: Articles 2–3, 5, 9–10, 12, 17, and 20; Clauses 13–14, Section II, “Final Provisions.”
- Tax Code of Ukraine No. 2755-VI: Article 44, Clause 296.10.
- Resolution No. 1336 of the Cabinet of Ministers of Ukraine, “On Ensuring Implementation of Article 10 of the Law of Ukraine ‘On the Use of Cash Register Equipment in Trade, Catering, and Services’”: Items 2 and 2-1 of the Resolution and Item 1 of the approved list.
- Order No. 547 of the Ministry of Finance of Ukraine on RRO and KORO registration: Sections II–III of the Procedure for registering and using RROs.
- Procedure for registering and maintaining settlement books and settlement transaction record books, approved by Order No. 547: Sections II–III.
- Order No. 317 of the Ministry of Finance of Ukraine and its approved Procedure for registering, maintaining the register of, and using PRROs: Sections II–V.
- Order No. 13 of the Ministry of Finance of Ukraine, dated January 21, 2016, and the Regulation on the Form and Content of Settlement Documents: Sections I–III, sales receipt and refund receipt forms.
- Order No. 496 of the Ministry of Finance of Ukraine on FOP inventory records: Sections I–II and the Inventory Record Form.
- Law of Ukraine “On Consumer Protection” No. 1023-XII: Part 11, Article 8 on settlement documents.
- Law of Ukraine “On Personal Data Protection” No. 2297-VI: Articles 6 and 11 on the purpose and legal grounds for processing customer contact details.








Go back to the previous step