From February 2026, new rules for sending tax notices-decisions will apply

From 26 February 2026, amendments to the procedure for sending tax notices-decisions (TNDs) will enter into force under Order of the Ministry of Finance No. 1204. These amendments take into account the digitalisation of tax procedures, expand electronic document flow and clarify the rules for determining the moment a TND is deemed served on the taxpayer.​

The State Tax Service has developed these changes to reduce the number of disputes regarding proper notification of taxpayers and to harmonise the procedure with legislation on electronic documents and the Tax Code. In practice, the updated procedure effectively introduces a “single window” of electronic communication between the tax authorities and taxpayers.​

Main innovations of the procedure

1. The electronic form becomes the primary method of sending TNDs: via the electronic taxpayer’s cabinet, while paper notices will be used only where there is no access to, or consent to, electronic interaction.​
2. The moment of service of a TND is linked to its appearance in the “Incoming documents” section of the electronic cabinet, regardless of whether it is actually read, which obliges taxpayers to monitor their cabinet regularly.​
3. For large taxpayers, a separate electronic channel with enhanced signatures and centralised document flow is introduced, with a gradual phase-out of postal dispatches in 2026.​
4. Each TND will receive a unique digital identifier synchronised with the STS databases and the electronic cabinet, which will facilitate work with amending returns and appeals.​
5. TNDs may be appealed directly via the electronic cabinet, with the possibility to attach electronic evidence and automatically generate confirmation of the complaint filing date.​

Practical consequences for taxpayers
For businesses, the changes mean not only streamlined document flow but also new risks: the moment of receipt of a TND will no longer depend on the fact of familiarisation, but only on its delivery to the electronic cabinet, so arguments about delays or absence of postal notices will no longer be effective. Missing the 10‑day administrative appeal period for TNDs sent via the electronic cabinet will have the same consequences as for paper documents, so companies should introduce daily monitoring of the electronic cabinet, especially where there is a high volume of transactions.​

For individual entrepreneurs the situation is simpler: tax decisions can also be monitored via the “Diia” mobile application, which is synchronised with the taxpayer’s electronic cabinet.​

Impact on court practice
The new procedure is likely to reduce the number of disputes about proper service of TNDs, which previously made up a significant share of administrative tax cases. At the same time, courts will face new tasks: assessing technical failures of the electronic cabinet, the taxpayer’s actual access to it and compliance with the document placement regulations, which will lead to more active use of digital evidence such as technical logs, reports, electronic certificates and delivery notifications.​

Digitalisation as a basis for administrative reform
The updated procedure for sending TNDs is part of a broader digital tax interaction strategy up to 2030, which envisages a gradual abandonment of paper correspondence between taxpayers and tax authorities. The new procedure logically continues the development of the Single Electronic Taxpayer’s Cabinet, intended to consolidate all notices, registers and reporting in a single digital environment, reducing state postal costs, speeding up administration and simultaneously increasing transparency and procedural discipline requirements for taxpayers.​

Potential implementation challenges
Despite optimistic expectations, a number of potential difficulties should be considered: not all taxpayers have stable access to electronic services (especially under martial law or in areas with unstable internet). There may be problems with user authentication via qualified e‑signatures and the trust services system during peak loads. Additional work is required on amending procedural rules on service and appeal periods, as well as adapting taxpayers’ internal IT systems for automatic tracking of TNDs, while the effectiveness of the new procedure will depend on the technical readiness of the tax authorities and their response speed to technical failures.​

Conclusions
The updated procedure for sending tax notices-decisions is an important stage in the digitalisation of tax administration, aimed at reducing bureaucracy, increasing procedural transparency and speeding up communication between the state and business. At the same time, the new rules increase the requirements for taxpayers’ vigilance: the electronic cabinet is turning from an auxiliary service into a fully legally significant environment that is integral to tax administration processes.​

If you have any questions or issues related to interpreting the new rules for sending TNDs, the time limits for their appeal or the procedure for electronic interaction with the STS, you should seek advice from a tax consultant or a lawyer experienced in handling tax disputes.

The author is Maksym Bahniuk, Head of the Tax and Customs Law Practice at the law firm “WINNER”.