Financial penalties for RRO/PRRO in 2026: what entrepreneurs need to know

The scope of application of RRO and PRRO has long gone beyond individual business types: today almost anyone who accepts cash or cards must factor in the cost of working without a cash register, since from 1 August 2025 full fines of 100% and 150% of the value of goods or services sold apply to everyone, depending on how often the infringement is repeated.

Legal framework and general approach
Financial sanctions for violating RRO/PRRO rules are set out in Article 17 of Law No. 265/95‑VR, which links the amount of the fine to the value of goods or services sold in breach of the rules, effectively making liability “turnover‑based”: the larger the receipt, the greater the hit to the business. From 1 August 2025 and therefore throughout 2026, these provisions apply to all entities performing settlement operations, and in addition to turnover‑based fines, fixed penalties (UAH 510, 5 100 etc.) apply for breaches related to receipt books, control tape and reporting, which are often imposed on top and significantly increase the overall burden.

100% and 150%: key fines in 2026
· 100% of the value of goods sold/services rendered – for the first detected violation.
· 150% of the value of goods sold/services rendered – for each subsequent violation.
· “Each subsequent” means each individual transaction with a breach, so the fine may be charged on every non‑fiscalised transaction, which in high‑volume sales quickly turns into tens or hundreds of thousands of hryvnias in losses.

Violations subject to these sanctions include:
· processing payments via RRO/PRRO or using receipt books for less than the full amount (partial fiscalisation);
· not processing transactions through RRO/PRRO in fiscal mode at all;
· failure to issue a fiscal receipt to the customer (paper or electronic);
· carrying out settlements without a receipt book in cases where its use is mandatory.

Thus, “non‑use of RRO/PRRO” covers both the complete absence of a cash register and any manipulation of the receipt amount or failure to issue a fiscal document.

Other financial sanctions related to RRO/PRRO
In addition to the main 100%/150% fines, businesses must take into account a number of fixed penalties that apply regardless of turnover, including:
UAH 510 – for the absence of a control tape (paper or electronic) or for distorted data in it;
UAH 510 – for failure to submit RRO/PRRO reports (Z‑reports, electronic reporting to the tax authority, etc.);
UAH 510 – for breaching the prescribed procedure for using receipt books or books of settlement operations;
UAH 5 100 – for processing payments through an RRO without programming the names of excisable goods with the relevant UKT ZED code, price and quantity;
UAH 5 100 – for using an RRO that has unauthorised structural or software modifications.

For traders in excisable goods, selling unrecorded excise products is particularly dangerous: the fine equals the full value of the batch sold. This is effectively another turnover‑based penalty that may be applied on top of sanctions for RRO/PRRO violations.

Martial law specifics and deferred sanctions
During martial law, the approach to RRO/PRRO fines was partly softened, but this does not mean there is no liability. The tax authorities explicitly state that such violations may be assessed after martial law ends, taking into account paragraph 52‑1 of sub‑section 10, section XX of the Tax Code. Those who deliberately ignored RRO/PRRO requirements, referring to “wartime reliefs”, risk receiving a consolidated package of fines in peacetime if they cannot provide documentary evidence that compliance was objectively impossible (lack of internet, occupation of the territory, etc.).

Who is at highest risk
The most vulnerable to sanctions are businesses with a large number of small cash or card transactions: retail trade, HoReCa, consumer services, and online shops with delivery and cash‑on‑delivery. For them, every non‑fiscal receipt becomes a separate fine equal to the full value of the purchase, and repeated breaches quickly push the sanction from 100% to 150%, which can not only wipe out profit but also create a debt exceeding revenue for the disputed period. A separate high‑risk group are simplified‑tax sole proprietors who have worked without RRO/PRRO for years, relying on exemptions; after full restoration of fines from August 2025, inspections in 2026 are likely to focus on them.

How to reduce fine risks in 2026
To minimise the likelihood of financial sanctions, businesses should implement practical safeguards:
– analyse whether their activities require RRO/PRRO and document this internally;
– choose an appropriate solution (hardware RRO vs. software PRRO) based on business scale;
– organise daily control of fiscalisation (Z‑reports, completeness of recorded revenue, receipts for each sales channel);
– train staff, since most “technical” breaches stem from cashier mistakes;
– conduct a separate audit of settings for excisable goods to avoid UAH 5 100 fines at each point of sale.

Practical takeaways for entrepreneurs
In 2026, operating without RRO/PRRO becomes a major strategic risk: 100% and 150% fines on turnover effectively act as an additional “turnover tax” that can fully absorb financial results. Consequently, spending on implementing and maintaining RRO/PRRO should be viewed as an insurance premium against much higher future losses, while investment in proper fiscalisation, staff training and periodic tax‑legal audits of settlement systems is an essential element of financial security.

If you have questions or issues related to using RRO/PRRO, assessing fine risks or appealing tax authority decisions, seek professional advice to analyse your situation and minimise potential consequences.
Author – Yuliia Popadyn, attorney in tax and housing law at the law firm “Legal Company ‘WINNER’.