RRO/PRRO: Full penalties of up to 150% of the sale value apply in 2026

Businesses that still rely on wartime relief measures related to RRO/PRRO should take note.

On 1 September, the State Tax Service of Ukraine once again reminded entrepreneurs of the level of liability for violations in processing settlement transactions.

The preferential period with reduced penalties ended on 31 July 2025.

In 2026, full financial penalties apply.

The following penalties are imposed for failing to process a settlement transaction through an RRO/PRRO, processing it for an incomplete amount, or failing to issue the required settlement document:

– 100% of the value of goods, works, or services sold in violation — for the first violation;
– 150% of the value — for each subsequent violation.

It is important for businesses to properly understand the scale of this risk.

The penalty is not calculated based on the amount of unpaid tax.

It is tied to the value of goods or services sold in violation of the rules.

For example, if during an inspection the State Tax Service establishes that goods worth UAH 100,000 were sold without being properly processed through an RRO/PRRO, the financial penalty for the first such violation may also amount to UAH 100,000.

For the next violation, the penalty will be 150% of the value of the relevant transaction.

Therefore, risk does not arise only in situations where a cash register is completely absent.

Problems may also occur when:

– a transaction is not processed through an RRO/PRRO;
– a receipt is issued for an incomplete amount;
– the customer is not provided with a settlement document;
– fiscalisation of certain payment methods is organised incorrectly.

Online stores, HoReCa businesses, retail companies, and businesses that accept several types of payments at the same time should be especially careful.

A bank card, POS terminal, payment through a website, payment link, or cash-on-delivery payment: the legal assessment of whether an RRO is required depends not merely on the fact that funds were received “cashlessly,” but on the specific payment mechanism.

The main mistake, therefore, is to assume that an RRO is automatically unnecessary if funds are received in a bank account.

Each payment-acceptance model must be assessed separately.

There is one more important point.

RRO-related violations are generally identified during on-site inspections.

That is why the payment model should be reviewed before inspectors arrive at a point of sale:

how the customer pays → where the funds are received → whether this is a settlement transaction → whether an RRO/PRRO is required → which document the customer receives.

With penalties of 100–150%, even a technical error can be costly.

It is better to seek legal advice now than to need legal representation later.

Would you like to check whether your business applies RRO/PRRO correctly and whether there are risks during an on-site inspection by the State Tax Service?

📞 Call: 096 574 81 02
📧 Email: info@uk-winner.com

Author — Yuliia Popadyn, Attorney-at-Law in the Tax and Housing Law Practice at WINNER Law Firm.