Blocking of tax invoices: new rules from September 2025

Legislative basis and motives for change
On August 26, 2025, the Cabinet of Ministers of Ukraine adopted Resolution No. 1048, which significantly changed the procedure for suspending the registration of tax invoices and adjustment calculations in the Unified Register. The updates relate to Resolution No. 1165 from 2019, which regulates the algorithm for blocking tax invoices, VAT payer risk criteria, the system of positive tax history, and methods of unblocking. The main goal is to optimize and liberalize procedures, protect bona fide businesses, and reduce the number of fictitious operations.

Main reasons for change:

• Increased pressure on business due to mass blocking of tax invoices in 2022–2024;
• Excessive manual checks and registration delays;
• The need for digitalization and automation of tax administration.

Key innovations and criteria
Limits for unconditional registration of tax invoices have been significantly changed:

• The monthly supply volume increased from UAH 500,000 to UAH 1 million.
• The supply amount per recipient increased from UAH 50,000 to UAH 100,000.
• The amount of VAT paid increased from UAH 20,000 to UAH 40,000, including the amount declared for the last month prior to the payment deadline.
• The director can now officially head up to five companies, previously up to three, without automatically being classified as “risky.”
• The threshold for registering small tax invoices has risen to UAH 10,000, and the monthly volume for micro-operations to UAH 3 million.

For enterprises operating in regions with potential threat of hostilities, automatic registration of invoices is provided—this is a significant relief for businesses in frontline areas.

Expansion of the concept of “positive tax history”
The criteria for acquiring and losing a “positive history” as a VAT payer have been detailed and expanded:

• Timely payment of taxes.
• No overdue reports.
• Working only with reliable counterparties.
• Prompt introduction of changes to company and activity data.

Businesses that meet these requirements have a greater chance to avoid invoice blocking in the new system.

Technical and procedural changes
The algorithm for calculating tax burden and integrating the VAT taxpayer’s data table has been updated. Automatic accounting of this data is provided in the consideration of unblocking issues after the risky status is removed.

• Some stages of repeated administrative appeals are canceled.
• A new form of decision on data table non-acceptance is introduced.
• The conditions for unblocking an invoice after the enterprise’s “rehabilitation” are leveled.

Risks of the new system
Immediately after the changes come into force, risks remain:

• Imperfect algorithms for automatic monitoring of taxpayers.
• Probability of being classified as “risky” due to atypical operations or new counterparties.
• Possible difficulties with the updated data table, especially for companies with complex business processes.
• Judicial practice on unblocking invoices remains relevant: if administrative resolution is impossible, companies have to go to court to confirm the right to a tax credit.

Practical advice for business

1. Carefully monitor compliance with the unconditional registration criteria.
2. Timely update all information about activity codes, types of activities, and owners.
3. Maintain an impeccable tax history and work only with verified partners.
4. Respond quickly to blocking: submit documents for unblocking and use the new automatic risk reversal procedure.

Conclusions and expected effect
The changes in the procedure for blocking tax invoices, effective from September 2025, are aimed at reducing administrative burden, minimizing the number of blocked invoices, and increasing process transparency for bona fide VAT payers. Most innovations are liberalization based on wartime realities, digitalization, and the demands of the present.

At the same time, businesses will need to adapt internal processes, strengthen control over tax risks, and automate the updating of registration data to respond promptly to the requirements of the tax authority.

Author — Maksym Bahniuk, Head of Tax and Customs Law Practice at the Law Firm “WINNER”.