The SOD RRO will determine which taxpayers the tax authorities will actually audit

In 2025, the State Tax Service of Ukraine enhanced control automation by expanding analytical selection of taxpayers for on-site inspections, and from 2026 the SOD RRO system will play a key role in this process as the main tool of risk‑based tax control and business tax risk formation.

What SOD RRO is and what information it accumulates
SOD RRO is a centralized system that collects and analyzes data from RRO and PRRO in real time (sales volumes, time and frequency of operations, average receipt, product range, taxation regime, place of activity, etc.), having evolved from a technical repository of fiscal receipts into an analytical hub that enables automatic selection of taxpayers for on-site inspections based on calculated risk indicators.

Principles of risk profile formation

1. Financial and operational anomalies: significantly lower volumes of RRO operations compared to peers or a sharp unjustified drop in revenue.
2. Behavioral indicators: atypical operating mode of RRO, sharp fluctuations in the number of receipts, frequent re-registrations of devices, unusual dynamics of the average receipt.
3. “Connected group” factor: detection of related individual entrepreneurs/companies by addresses, PRRO accounts, IP addresses or personnel and formation of a “risk cluster”.
4. Comparison of official and actual flows: cross-check of RRO data with VAT, single tax and social contribution reporting; material discrepancies classify the entity as high‑risk.
5. The taxpayer’s profile is additionally refined through integration of SOD RRO with other analytical systems of the State Tax Service, which makes it possible to assess the statistical probability of violations.

New procedure for initiating on-site inspections
The key practical change is the almost complete elimination of the “human factor” in initiating on-site inspections: whereas previously the grounds were citizens’ complaints or law‑enforcement materials, now inspections are launched by the system, which, based on automatic risk scoring, generates an electronic submission, while an official only approves it and issues an order without changing the formal grounds set out in Articles 80–81 of the Tax Code of Ukraine.

Implications for business

1. The risk of “automatic” inspections increases, and businesses do not always understand which specific anomaly triggered inclusion in the risk list.
2. Requirements for accounting discipline are tightening: proper PRRO settings, alignment with bookkeeping and correct product categorization are needed.
3. Preventive analytics becomes essential, meaning regular self‑monitoring of RRO indicators and detection of discrepancies between cash register and tax data.
4. The issue of evidentiary standards becomes more acute, since the opacity of analytical criteria may lead to litigation regarding the legality of inspection orders.

Outlook for further development
SOD RRO is gradually becoming the core of an integrated digital tax control model, and in future it is planned to be strengthened by connecting acquiring data, the fuel expenses register and excisable goods control systems, which will significantly expand tax monitoring and make manipulation of accounting in trade or services almost impossible without a technical trace, while at the same time a high risk of algorithm “false positives” will remain, so proving good‑faith conduct through legal instruments will continue to be a key condition for business security.

Recommendations for business entities
Check PRRO settings and the accuracy of registration data in SOD RRO.
Avoid systematic errors in fiscal receipts (incorrect UKT ZED codes, VAT rates, price mismatches).
Conduct internal audits of the regularity and completeness of transaction fiscalization.
Keep a cash‑register event log and record all PRRO technical failures, deferred receipts and service interruptions.
Document internal decisions on changes in RRO operating mode, as this evidence may become an argument during an inspection.
Introduce personal liability of cashiers and managers for the accuracy of data in receipts.

Conclusion
The SOD RRO system is fundamentally transforming tax control in Ukraine by making taxpayer selection for inspections more structured, rapid and technically justified, which in the long term will improve tax discipline while requiring businesses to carefully manage their digital footprints, since shifting control into the realm of algorithms and data increases efficiency but also reinforces the need for legal protection against possible analytical errors.

If you have any questions or issues related to applying the SOD RRO system, risks of on-site inspections or preparation for tax control, please contact our tax law experts for advice.

Author – Yuliia Popadyn, attorney in the tax and housing law practice of the law firm “Legal Company WINNER”.