New rules for preparing work completion certificates

The act of completed works (services rendered) remains one of the key primary documents confirming the fact of a business transaction. It is this document that forms the basis for accounting of expenses, tax credit, and determining the moment of revenue recognition. In 2025, the rules for its execution underwent significant changes as part of the reform of approaches to primary documentation and the transition of businesses to digital accounting formats.

Regulatory framework
The procedure for executing acts of completed works is traditionally regulated by the Law of Ukraine “On Accounting and Financial Reporting in Ukraine” No. 996‑XIV, the Tax Code of Ukraine (Articles 44, 198, 201), as well as sectoral accounting standards. In addition, starting from 2025, the amendments introduced by Order of the Ministry of Finance of Ukraine No. 388 of 17 September 2024 entered into force, updating the requirements for the requisites of primary documents and the procedure for their maintenance. The key focus is on eliminating duplication of paper and electronic forms, strengthening the legal force of electronic documents, and unifying the requirements for digital signatures.

Mandatory details: what remained and what changed
According to the updated requirements, an act of completed works, regardless of its form (paper or electronic), must contain the following mandatory details:

name of the document and its number;

date of drawing up;

description of the essence of the business transaction (list of works performed or services rendered);

unit of measurement, quantity, cost excluding VAT and total amount;

signatures (including electronic) of responsible persons of both parties.

A new requirement is to indicate in the field “Grounds for drawing up” an exact reference to the contract within which the works were performed. This makes it possible to clearly link the act to a specific obligation and simplifies inspections for both internal and tax control. The list of persons authorized to sign the act has also been expanded: now it may be not only the director or chief accountant, but also an authorized employee under a power of attorney, including one executed in electronic form.

Electronic act: legal force and requirements
An important innovation of 2025 is the full equivalence of an electronic act to its paper analogue. In accordance with the Law “On Electronic Documents and Electronic Document Flow”, a document signed with a qualified electronic signature (QES) has equal legal force and does not require duplication on paper. The new rules provide that the date of drawing up an electronic act is determined by the moment when the last electronic signature is affixed. This is crucial for accounting and tax purposes, as it affects the determination of the period for recognition of income and expenses; in tax accounting, the key date is the date of the counterparty’s last signature rather than the date when the draft act was generated. For employers using cloud services or specialized document‑management systems, there is a technical possibility to store acts on secure electronic platforms that comply with personal‑data protection legislation.

Reconciliation of discrepancies and refusal to sign
The new rules specify the procedure for reconciling acts and recording refusals to sign. If a party disagrees with the scope or quality of the works, it must notify the other party in writing within five business days from the moment of receiving the act. If the refusal is unsubstantiated or the deadline is missed, the act is deemed agreed and has legal force. In electronic document flow, the same approach applies: if no reasoned objection is received from the counterparty through the electronic exchange system, the act is considered accepted by default. This significantly simplifies business interactions between companies engaged in large‑scale or mass operations.

Tax aspects: focus on reliability
The tax authorities emphasize that an act of completed works is not an independent basis for recognizing a tax credit, but it is a key piece of evidence confirming that services have actually been rendered. Recognition of expenses and income is possible only if the reality of the transaction is confirmed, meaning that the act must correspond to the parties’ actual actions. Deficiencies in execution, missing mandatory details, or missing signatures may serve as grounds for disallowing expenses or rejecting the tax credit. Therefore, legal entities must ensure proper internal verification of acts already at the stage of their preparation.

Practical recommendations for business
To avoid disputes with counterparties and tax authorities in 2025, lawyers and accountants recommend:

ensuring a unified internal template of acts that complies with the updated requirements of the Ministry of Finance;

revising contract templates to include provisions on electronic document flow;

using only QES issued by certified trust service providers;

recording the process of act reconciliation within the corporate document‑management system;

checking the correct indication of contracts, scope of works, units of measurement, and value indicators;

storing acts for at least three years, regardless of the form in which they are drawn up.

Special attention should be paid to documents drawn up with non‑residents: in such cases, translation into Ukrainian and certification of the correspondence of the data to the primary documents of the foreign party are mandatory.

Liability for violations
Improper execution of acts may lead to administrative and financial liability. Under Article 164‑2 of the Code of Ukraine on Administrative Offences, violation of the rules for maintaining accounting records and preparing primary documents entails a fine ranging from 8 to 15 tax‑exempt minimum incomes of citizens (from 136 to 255 hryvnias), and in case of repeated violation – up to 425 hryvnias. In the tax sphere, incorrect execution of acts may become grounds for additional assessment of corporate income tax or VAT, and in court it may lead to recognition of the contract as unperformed or to its termination at the customer’s initiative.

Prospects of automation
Trends show that the execution of acts is gradually moving into a fully digital environment. Starting from 2026, the Ministry of Economy plans to introduce a unified standard of the electronic structure of an act in XML format, which will allow integrating document flow between different accounting systems. This approach will minimize the human factor, speed up contract signing, and reduce the risk of errors in primary documents.

Conclusion
The new rules for executing acts of completed works significantly strengthen discipline in accounting and contractual relations while opening the way for businesses to fully digitalize document flow. For companies seeking to avoid risks, it is important to update internal templates now, verify electronic signature systems, and train responsible staff to work under the new standards.

Author – Yuliia Popadyn, attorney in the tax and housing law practice of the law firm “Legal Company ‘WINNER’”. If you have questions or issues related to the execution of acts of completed works, electronic document flow, or verification of primary documents, contact the Winner Law Firm legal team for individual advice and practical assistance.