Sale of goods through marketplaces: is an RRO/PRRO required?

With the spread of online trade, most entrepreneurs in Ukraine have partially or completely switched to a digital format of sales.  Platforms such as Rozetka, Prom, Epicentr, Allo, OLX and others have become an effective sales channel for businesses, allowing them to reach thousands of customers without maintaining a physical outlet.  At the same time, as sales volumes grow, questions arise regarding the fiscalization of transactions, namely when and in which cases it is necessary to use a cash register (RRO) or its electronic version, the software RRO (PRRO).

Who is obliged to use RRO/PRRO when selling through marketplaces  The requirement to use RRO/PRRO depends primarily on the form of payment.  If payment for goods is received by bank transfer without the use of payment cards or POS terminals – for example, to a sole proprietor’s current account by IBAN – there is no obligation to fiscalize the sale.  However, if the buyer makes a payment via internet acquiring, a payment system (WayForPay, LiqPay, Portmone, etc.) or a courier accepts cash/bank card upon delivery, this is already considered a settlement transaction.  Accordingly, the seller, even if operating through a marketplace, must register and use PRRO.

However, it is important to distinguish who exactly fiscalizes the transaction: the seller or the marketplace.  If the platform acts as an intermediary and it is the one that receives funds from buyers and then transfers the amounts to the seller minus commission, the obligation to use RRO/PRRO may rest with the marketplace.  If the funds are credited directly to the seller, even in digital form, fiscalization is the seller’s responsibility.

Position of the tax authority and court practice  The State Tax Service in its clarifications consistently emphasizes that an RRO or PRRO is required in any case when settlements are made using electronic payment instruments.  In 2024–2025, Ukrainian courts have repeatedly supported this position, noting that online payments are equated to settlement transactions regardless of where exactly the sale is carried out – on the seller’s own website or via a marketplace.

Therefore, one should not expect that trading on popular marketplaces automatically exempts from the obligation to use PRRO.  Each situation requires analysis of the platform agreement, the method of receiving funds and the type of customers.

How businesses should act

• Check the format of settlements with clients: bank transfer to the account or transaction via acquiring.
• Review the marketplace public offer agreement to see who accepts the payment.
• If necessary, register PRRO and train managers to use it.
• Clarify which documents (receipt, waybill, acceptance certificate) must be provided to customers.

Advice from WINNER.

At Winner, we regularly support businesses on matters of fiscalization and online commerce.  We help review agreements with marketplaces, assess financial risks, and ensure lawful use of RRO/PRRO without fines.

If your business sells goods online and you are not sure whether your settlement scheme is correct, contact WINNER’s lawyers.  We will help determine the optimal fiscalization format and prevent claims from supervisory authorities.

Author – Yuliia Popadyn, attorney of the tax and housing law practice at the Law Firm “Winner Legal Company”.