New tax invoice registration rules 2025: how the changes in Resolution No.1048 will affect business

From September 27, 2025, new rules for the registration of tax invoices and adjustment calculations in the Unified Register of Tax Invoices (URTI) come into force in Ukraine, introduced by Cabinet Resolution No. 1048. Their purpose is to reduce bureaucracy, increase procedural transparency, and make the VAT administration system more business-friendly, especially for small and medium-sized enterprises. Below is a complete analytical overview of the key changes, their practical significance, and their potential impact for business.

Why Are Changes Needed?
Widespread criticism and dissatisfaction over mass blocking of tax invoices and vague risk criteria have long hindered honest business in Ukraine. Frequent, non-transparent registration stoppages of tax invoices created additional burden and risk for taxpayers, especially SMEs, exporters, and companies from high-risk regions. Taking this into account, the government now shifts its focus towards encouraging bona fide payers and reducing invoice blockages.

Main Changes from September 27, 2025
The reform contains several comprehensive innovations affecting both general limits for invoice registration and specific procedures for certain taxpayer categories:

1. Increase of Limits for Unconditional Invoice Registration:

• The monthly supply threshold for unconditional registration increases to UAH 1 million (previously UAH 500,000).
• The counterparty limit is now UAH 100,000 (was UAH 50,000).

2. Changes for Low-Value Transactions:

• The threshold for a single invoice for small transactions rises from UAH 5,000 to UAH 10,000.
• The total volume of such transactions for one payer per month may now reach UAH 3 million (previously UAH 500,000).

3. Changes in Risk Assessment and Managers:

• Expanded conditions allow one individual to be a director in up to 5 companies (instead of 3) without automatic “risk” recognition.
• Risk criteria for region and sector have been clarified.

4. New Rules for Exporters and Companies from Risk Areas:

• Requirements for unconditional registration of invoices on export operations—especially for businesses in risk zones (excluding active war zones)—have been significantly liberalized.
• Return of goods from non-VAT payers allowed up to 90 days without automatic risk classification (previously 30 days).

5. Liberalization for Sole Proprietors and Microbusinesses:

• Higher limits and simplified criteria will have a particularly positive effect for sole proprietors (FOP) and small businesses.

How Will the Registration Procedure Change?
Tax invoice registration will continue via electronic form completion and a qualified e-signature. The invoice is then sent through the VAT administration system to the State Tax Service for inclusion in the register. However, with updated risk criteria and higher limits for certain transactions, the likelihood of automated suspension or blocking is now minimized.

Strategic Business Implications

1. Fewer blocks—fewer losses. More transparent and liberal limits let businesses plan transactions without sudden halts, reducing cash flow delay and risk of sanctions.
2. SME support. The updates make business easier for sole proprietors and companies with medium/low operation intensity, who often fell under “suspicion” due only to transaction counts or small values.
3. Improved investment attractiveness. Reduced bureaucracy enables resources to be directed toward business development, not legal disputes or invoice blocks.

Who Will Be Most Affected?

• Entrepreneurs and SMEs with numerous transactions near the old thresholds.
• Directors with multiple businesses and companies in border/risk regions.
• Exporters and businesses with an extensive counterparty network.

Potential Issues and Further Considerations

• Implementation will not be instant: IT systems must adapt, accountants must be trained, and internal rules updated.
• Risks of blocking may still exist for large amounts or specific industries.

Conclusion
The updated rules are a decisive step towards transparency, liberalization, and support of bona fide business in Ukraine. In the near term, these changes will simplify life for sole proprietors, SMEs, exporters, and companies from higher-risk areas, reducing losses and freeing up “frozen” funds from invoice blocks. Such steps make Ukraine more attractive for investment and give businesses more confidence and stability.

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