Briefing document & Podcast: E-Invoicing and E-Reporting in Ukraine

SUMMARY

I. Executive Summary

Ukraine has been progressively implementing electronic invoicing and reporting requirements. Mandatory e-invoicing for B2G transactions started in 2011, and for most B2B and B2C transactions (above a VAT threshold) in 2015. A full VAT invoice digitization was in place by 2018. The country is now transitioning to a digital audit system with the introduction of SAF-T reporting. SAF-T reporting will be mandatory for large taxpayers starting January 1, 2025, and for all VAT-registered taxpayers by January 1, 2027. The system encompasses domestic, export, and import transactions. Compliance is strictly enforced, with penalties for late registration, failure to register, and SAF-T non-compliance. Businesses are also obligated to securely archive all electronic invoices and related tax documents for a minimum of 5 years. Currently, Ukraine does not provide pre-filled VAT returns.

II. Implementation Timeline:

2011: Mandatory e-invoicing for Business-to-Government (B2G) transactions.
2015: Introduction of the Unified Register of Tax Invoices (URTI) for B2B/B2C transactions exceeding UAH 1 million annual revenue. This effectively mandated e-invoicing for most B2B and B2C transactions above the VAT registration threshold.
2018: Full VAT invoice digitization. All VAT-registered taxpayers were required to issue tax invoices electronically and submit them to the tax authority before or at the time of issuing them to customers.
2020-2022: Grace period during the COVID-19 pandemic and the outbreak of war, with temporary suspension or relaxation of e-invoice reporting deadlines. A moratorium on fines was in effect from March 2020 through May 26, 2022, with a grace period until July 15, 2022, to register backlogged invoices from February-May 2022 without penalty.
2023: Introduction of an optional Standard Audit File for Tax (SAF-T) reporting system as a pilot.
2025: SAF-T mandate for large taxpayers effective January 1, 2025.
- “Large companies must submit a comprehensive SAF-T report (in standard XML format) periodically – with an annual filing requirement kicking off in 2025 – and continue to provide SAF-T data on-demand during audits (within 2 business days of a request).”
2027: Full SAF-T mandate for all VAT-registered taxpayers effective January 1, 2027.

III. Scope of Transactions Covered:

Domestic B2B and B2C: All domestic sales of goods and services between businesses (B2B) or to consumers (B2C) are subject to the electronic invoicing mandate once the supplier crosses the revenue threshold for VAT registration (UAH 1 million).
Business-to-Government (B2G): E‑invoicing has been mandatory for all B2G transactions since 2011.
Cross-Border Transactions: The system encompasses cross-border trade, including export invoices and import transactions. “In summary, domestic, export, and import transactions all fall within the e‑invoicing/e-reporting scope in one form or another, ensuring comprehensive coverage of taxable events.”

IV. Taxable Persons in Scope:

Ukrainian Businesses (Established): All resident companies and entrepreneurs registered for VAT in Ukraine are subject to e-invoicing and SAF-T requirements, according to their size.
Foreign & Non-Established Entities: Non-established companies are generally not forced into e-invoicing unless they become VAT-registered for Ukrainian VAT. Foreign providers of B2C digital services are required to register for VAT if their annual Ukraine turnover exceeds UAH 1 million. “Once a foreign entity registers for VAT it is treated like a domestic VAT payer – meaning it must issue Ukrainian-compliant tax invoices for its supplies and report them via the URTI system.”

V. E-Invoice Format and Data Requirements:

Format: E‑invoices are issued in a structured XML format, aligning with international standards like UBL (Universal Business Language) and PEPPOL BIS 3.0. Every e-invoice must be digitally signed.
Mandatory Invoice Fields:
- Invoice identification (unique serial/number and date)
- Supplier and Buyer details (names, addresses, VAT numbers)
- Description of goods/services (quantity, unit prices)
- Tax base and rate (net amount, VAT rate, VAT amount)
- Totals (total invoice amount including VAT)
- Commodity code (UCC FEA for goods, when applicable)
- Other specifics (tax exemption note, reverse charge indication)
- E-Reporting (SAF-T) Data: A SAF-T (Standard Audit File for Tax) is essentially a comprehensive accounting data file in XML. In Ukraine’s case, the SAF-T UA includes: detailed general ledger entries, complete lists of sales and purchase invoices and credit notes, records of payments, fixed asset registers, inventory movements, and tax adjustments.

VI. Invoice Submission Process and Deadlines:

Real-Time Reporting via URTI: Ukraine’s e-invoicing uses a clearance model. Invoices are submitted electronically to URTI for registration and validation, essentially at the time of issuance.
Deadline to Register Invoices: Strict timelines are defined in the Tax Code (Article 201.10). “Currently, due to adjustments for the wartime situation, the schedule is: if an invoice is issued from the 1st to 15th of a month, it must be registered by the 5th of the following month; if issued from the 16th to month’s end, it must be registered by the 18th of the following month.”
Transmission Mechanism: Businesses can connect to URTI through licensed accounting software, certified providers, or via the State Tax Service’s electronic cabinet.
E-Reporting Submission Timing: Large taxpayers must submit an annual SAF-T file from 2025. Any taxpayer must be ready to generate and submit a SAF-T file on-demand within 2 business days if requested. By 2027, periodic SAF-T submissions for all taxpayers will be routine.

VII. Grace Periods and Transitional Measures:

Phased Rollouts: Ukraine has generally introduced mandates in phases. “For example, the SAF-T requirement is phased: large companies in 2025, all companies by 2027. This gives smaller businesses extra time (~2 years) to adapt their systems before they are obligated to file SAF-T.”
War and Emergency Provisions: During the COVID-19 quarantine and the early phase of the 2022 war, Ukraine suspended most tax penalties and extended filing deadlines, including for e-invoice registrations. “Specifically, invoices that fell due in the first months of the war (Feb–May 2022) were allowed to be registered by July 15, 2022 with no late fines.”
No Ongoing “Soft Enforcement” Grace: Aside from war-time relief and scheduled phase-ins, there is no indefinite grace period for compliance.

VIII. Penalties for Non-Compliance:

Late Invoice Registration: Monetary fines are imposed for late submission of e-invoices to the URTI, typically a percentage of the VAT amount on the invoice.
Failure to Register/Issue Invoices: Not reporting an invoice at all is a serious offense, resulting in fines and the buyer losing the right to deduct VAT.
SAF-T Non-Compliance: Failing to submit the SAF-T file when required, or not adhering to the prescribed format/procedure, can lead to fines.

IX. Archiving Requirements and Retention Period:

Archiving Obligation: Taxpayers must securely archive all electronic invoices and related tax documents for a specified retention period.
Retention Period: Most tax and accounting documents (including invoices, ledgers, filings) must now be kept for 5 years (1,825 days), aligning with the standard period within which the tax authorities can audit VAT.
Format of Archiving: Invoices must be preserved in their original electronic form, complete with the digital signature and timestamp.

X. Pre-Filled VAT Returns:

No Pre-Populated Returns (Currently): Ukraine does not provide pre-filled VAT returns to taxpayers, despite receiving all invoice data in real-time. The onus remains on the taxpayer to compile their VAT return. “No part of the VAT return is prefilled by the tax authority – the taxpayer bears full responsibility for declaring the correct totals (and then the authority cross-checks after submission).”
Cross-Checks vs. Prefill: The State Tax Service uses e-invoice data to cross-verify VAT declarations.

XI. References & Sources:

The information presented is based on the following references and sources:

The Tax Code of Ukraine (Article 201, Article 69)
Amendment Laws (Law No. 1014-IX, Law No. 6255/2021, Law No. 2260-IX, Law No. 2876-IX)
Guidance from the State Tax Service (STS)
Reports from global consultancies and VAT specialists (VATupdate, KPMG, EDICOM, Spaceinvoices, Storecove)

This briefing document provides a high-level overview and should not be considered legal or financial advice. Businesses operating in Ukraine are advised to consult with qualified professionals to ensure compliance with all applicable regulations.

INDEPTH ANALYSIS

Implementation Timeline (Past, Current & Upcoming)

2011 – B2G E‑Invoicing: Electronic invoicing became mandatory for all business-to-government invoices in Ukraine, requiring suppliers to government to use e‑invoices. [edicomgroup.com]
2015 – Introduction of URTI for B2B/B2C: Ukraine launched the Unified Register of Tax Invoices (URTI) system. Since July 2015, all VAT-registered businesses exceeding UAH 1 million annual revenue must electronically report their sales invoices via URTI. This effectively mandated e‑invoicing (i.e. electronic tax invoice issuance and reporting) for most B2B and B2C transactions above the VAT registration threshold. Non-compliance from this date carried penalties and could jeopardize VAT recovery on improperly reported invoices. Smaller businesses below the threshold could continue using paper invoices, though many adopted e‑invoicing voluntarily. [vatupdate.com] [comarch.com], [vatcalc.com] [spaceinvoices.com]
2018 – Full VAT Invoice Digitization: By 2018, Ukraine’s real-time VAT invoice reporting was firmly in place. All VAT-registered taxpayers (whether domestic companies or registered non-residents) were effectively required to issue tax invoices electronically and submit them to the tax authority before or at the time of issuing them to customers. This ensured that virtually all taxable transactions by VAT payers were captured in the URTI system for tax control. [openenvoy.com], [openenvoy.com]
2020–2022 – Grace Period During Crises: During the COVID-19 pandemic and the outbreak of war in 2022, Ukraine temporarily suspended or relaxed enforcement of e‑invoice reporting deadlines. A moratorium on fines was in effect from March 2020 through May 26, 2022. The obligation to register invoices in URTI was briefly suspended at the start of the war and then reinstated mid-2022, with businesses given a grace window (until July 15, 2022) to register any backlogged invoices from February–May 2022 without penalty. After this catch-up period, normal mandatory registration and penalties resumed (for those able to comply despite martial law). [tax.gov.ua], [tax.gov.ua] [tax.gov.ua], [vatcalc.com] [tax.gov.ua]
2023 – Transition to Digital Audit (SAF-T): Ukraine introduced an optional Standard Audit File for Tax (SAF-T) reporting system in 2023 as a pilot. Large taxpayers could be asked to generate SAF-T files on demand, and the tax authority prepared systems (the “Taxpayer e-cabinet”) for broader SAF-T rollout. [rtcsuite.com], [rtcsuite.com]
2025 – SAF-T Mandate for Large Taxpayers: Effective 1 January 2025, SAF-T electronic reporting becomes mandatory for large taxpayers in Ukraine. Large companies must submit a comprehensive SAF-T report (in standard XML format) periodically – with an annual filing requirement kicking off in 2025 – and continue to provide SAF-T data on-demand during audits (within 2 business days of a request). This marks the start of Ukraine’s “e-Reporting” mandate beyond just invoicing. [edicomgroup.com], [kpmg.com] [rtcsuite.com], [rtcsuite.com]
2027 – Full SAF-T for All Businesses: By 1 January 2027, the SAF-T mandate will extend to all VAT-registered taxpayers. From 2027 onward, every business registered for VAT in Ukraine must periodically submit standardized audit files (with content defined by law) to the tax authorities. This two-year phase-in (2025–27) is effectively the grace period for small and medium businesses to prepare for digital reporting. No separate “grace period” beyond this phased timeline is expected – by 2027 compliance will be compulsory for everyone. [edicomgroup.com], [kpmg.com]

Scope of Transactions Covered

Domestic B2B and B2C: All domestic sales of goods and services between businesses (B2B) or to consumers (B2C) are subject to the electronic invoicing mandate once the supplier crosses the revenue threshold for VAT registration (UAH 1 million). In practice, this means any VAT-registered enterprise must issue a proper electronic tax invoice for every taxable transaction and report it via URTI. Smaller enterprises below the threshold (and not VAT-registered) are outside the mandate until they voluntarily or mandatorily register for VAT. [spaceinvoices.com], [spaceinvoices.com]
Business-to-Government (B2G): E‑invoicing has been mandatory for all B2G transactions since 2011. Any invoice issued to public sector entities must be electronic and lodged with the government’s systems. Ukraine’s public procurement platform (ProZorro) is integrated with this, ensuring government suppliers use e‑invoices by default. [edicomgroup.com]
Cross-Border Transactions: The Ukrainian system also encompasses cross-border trade for VAT purposes. Export invoices (which are usually zero-rated) must be issued as tax invoices and registered in URTI like domestic sales. Similarly, import transactions are captured: import VAT is administered via customs, but if an import requires a self-issued tax invoice or adjustment (e.g. for certain self-assessed supplies), those documents must be entered into URTI as well. In summary, domestic, export, and import transactions all fall within the e‑invoicing/e-reporting scope in one form or another, ensuring comprehensive coverage of taxable events. (Retail cash transactions are handled via cash registers, but any resulting tax invoices still feed into the system as needed.) [vatcalc.com]

Taxable Persons in Scope (Established vs. Non-Established)

Ukrainian Businesses (Established): All resident companies and entrepreneurs registered for VAT in Ukraine are subject to the e‑invoicing requirements. Once registered, a business must comply with issuing tax invoices electronically for its taxable supplies and with the SAF-T reporting obligations according to its size. This includes large taxpayers, SMEs, and any VAT-registered entity above the small-business threshold. (Certain small businesses not registered for VAT are outside the system entirely until they register.) [spaceinvoices.com], [spaceinvoices.com]
Foreign & Non-Established Entities: Non-established companies without a permanent establishment in Ukraine generally are not forced into e‑invoicing unless they become VAT-registered for Ukrainian VAT. Notably, foreign providers of B2C digital services are required to register for VAT if their annual Ukraine turnover exceeds UAH 1 million, which brings them into the tax system. Once a foreign entity registers for VAT (e.g. via a tax representative or the special electronic services registration), it is treated like a domestic VAT payer – meaning it must issue Ukrainian-compliant tax invoices for its supplies and report them via the URTI system. In other words, a registered non-resident has the same e‑invoicing obligations as local firms. (If a non-resident never registers and just exports goods to Ukraine under DDP arrangements, the import VAT is handled by the importer; only those with a Ukrainian VAT number need to issue tax invoices.) [spaceinvoices.com] [spaceinvoices.com], [spaceinvoices.com]
Established vs. Non-Established Summary: Established Ukrainian VAT taxpayers are fully in scope. Non-established businesses are in scope only if they have a Ukrainian VAT registration or fixed establishment. Those foreign businesses registered for VAT (for example, under the new digital services rules) must comply with electronic invoicing and reporting just as a local company would. There is no separate, lighter regime for non-residents—compliance (including invoice content, deadlines, and SAF-T filings) is expected equally once they are in the system. Failure of a required non-resident to register or comply can lead to significant penalties (for instance, not registering when required can trigger a fine equal to 30 minimum wages in Ukraine). [spaceinvoices.com]

E-Invoice Format and Data Requirements

Format: Ukrainian e‑invoices are issued in a structured XML format that aligns with international standards. The accepted formats include UBL (Universal Business Language) and PEPPOL BIS 3.0 (the EU standard) for compatibility. In practice, businesses prepare invoices using software or an ERP that connects to the URTI platform via API. There is no single government-provided template that must be used; instead, the data must conform to the schema and be transmitted to the tax authority’s system electronically. Every e-invoice must be digitally signed with the issuer’s authorized electronic signature certificate to ensure its authenticity and integrity. This digital signature requirement means the invoice’s origin and contents are verifiable and tamper-evident, as mandated by Ukrainian law. [spaceinvoices.com] [edicomgroup.com], [openenvoy.com]
Mandatory Invoice Fields: Electronic invoices (so-called “tax invoices”) in Ukraine must contain all the information required by the Tax Code. This includes:
- Invoice identification – a unique serial/number and the date of issuance. [edicomgroup.com]
- Supplier and Buyer details – names (or official entity names), addresses, and tax identification numbers (VAT numbers) of both the seller and the purchaser. [edicomgroup.com]
- Description of goods/services – a clear description of the items or services supplied, including quantity or volume and unit prices. [edicomgroup.com]
- Tax base and rate – the net amount (price excluding VAT) for each item, the applicable VAT rate (e.g. 20%, 7%, 14%, 0%), and the VAT amount calculated. Each VAT rate’s amount should be specified (for example, if some items are zero-rated and some standard-rated, they are listed separately). [edicomgroup.com]
- Totals – the total invoice amount including VAT (gross total), and typically the total VAT amount as a summary. [edicomgroup.com]
- Commodity code – for goods, the Ukrainian UCC FEA (commodity code) must be included, aligning with customs nomenclature, when applicable. [edicomgroup.com]
- Other specifics – any special tax exemption note if applicable, or indication if the supply is subject to reverse charge or other mechanism. (Additionally, Ukrainian tax invoices also distinguish whether the transaction is subject to domestic VAT, zero-rated export, etc., but these are implicit in the VAT rate and wording on the invoice.)
  These details are filed in structured form. Omission or errors in mandatory fields can lead to rejection of the e-invoice by the system. The invoice data submitted to the URTI is the basis for both parties’ VAT accounting (the seller’s VAT liability and the buyer’s VAT credit), so accuracy is critical.
E-Reporting (SAF-T) Data: The SAF-T reports, when required, contain much more extensive data beyond individual invoices. A SAF-T (Standard Audit File for Tax) is essentially a comprehensive accounting data file in XML. In Ukraine’s case, the SAF-T UA includes: detailed general ledger entries, complete lists of sales and purchase invoices and credit notes, records of payments, fixed asset registers, inventory movements, and tax adjustments. It covers accounting policies and all transaction metadata (dates, document numbers, amounts, counterparties) for the period. In short, all financial and tax records that substantiate the VAT returns must be structured and provided. This e-reporting data gives the tax authorities a full audit trail of a company’s activities, beyond just invoice fields. (For example, SAF-T will report transactions by account, link to source documents, and even include information on any non-VAT transactions or adjustments.) The format for SAF-T UA is defined by the authorities (based on an OECD XML schema), and an updated SAF-T UA 2.0 schema was introduced in late 2024 to streamline the reporting. Businesses must generate their SAF-T files according to this format when submitting e-reports. [rtcsuite.com], [kpmg.com] [kpmg.com] [rtcsuite.com], [rtcsuite.com]

Invoice Submission Process and Deadlines

Real-Time Reporting via URTI: Ukraine’s e-invoicing works on a clearance model. Invoices are submitted electronically to the Unified Register of Tax Invoices (URTI) for registration and validation with the tax authorities, essentially at the time of issuance. In practice, a company will prepare an invoice in its system, send it via API to the URTI, and once it’s successfully registered (acknowledged by the tax authority), the seller can then deliver the invoice to the buyer (often the buyer also gets it via the system). This real-time or near-real-time transmission ensures the tax authority receives all invoice data almost concurrently with the transaction. It greatly increases VAT compliance, as every invoice is “on the radar” of the tax service. [openenvoy.com], [openenvoy.com]
Deadline to Register Invoices: By law, every tax invoice must be registered in the URTI within strict timelines defined in the Tax Code (Article 201.10). Under normal circumstances, these deadlines are tied to the invoice date and the reporting period. Currently, due to adjustments for the wartime situation, the schedule is: if an invoice is issued from the 1st to 15th of a month, it must be registered by the 5th of the following month; if issued from the 16th to month’s end, it must be registered by the 18th of the following month. (These slightly extended deadlines were set by Law No. 2876-IX of Jan 2023 as a temporary measure during martial law. In peacetime, the cut-offs were somewhat tighter – effectively around 15 days after month end.) Importantly, certain internal adjustments and self-charge invoices have their own deadline (20 days after the month of issue, unchanged even during war). The key point is that there is a short window after invoice issuance in which you must report it, or it’s considered late. In practice, many companies register invoices immediately upon issuance to avoid any risk. The URTI system operates daily (with defined hours of availability) and provides a timestamped receipt when an invoice is accepted or if it’s rejected for errors. [firstaccou…ing.com.ua]
Transmission Mechanism: Businesses can connect to URTI either through licensed accounting software, certified providers (some use the PEPPOL network and access points to interface with URTI), or via the State Tax Service’s electronic cabinet. The data is transmitted in XML and the system performs format and validity checks. If all checks pass, the invoice is assigned a registration number and timestamp in URTI. Only a registered tax invoice is valid for VAT purposes (the buyer needs the URTI-registered document to claim input VAT). This means the e-invoice sent to the buyer includes the URTI registration details as proof. No paper copy is needed once it’s in URTI, and indeed the goal is a paperless process. [spaceinvoices.com], [spaceinvoices.com]
E-Reporting Submission Timing: For SAF-T and other e-reports, the timelines are less continuous and more periodic. Large taxpayers from 2025 must submit an annual SAF-T file (covering the full year’s financial data) – the first such file likely to be due in early 2026 for the year 2025 (the exact due date is set by regulations; often it might coincide with annual tax return deadlines). In addition, any taxpayer must be ready to generate and submit a SAF-T file on-demand within 2 business days if the tax authority requests it (usually in context of an audit or verification). By 2027, periodic SAF-T submissions for all taxpayers will be routine, though details (e.g. quarterly vs annual submissions for non-large businesses) will be clarified by the tax authorities’ guidelines. All these reports are transmitted electronically through the same tax authority e-cabinet or other secure channels. There is currently no separate “invoice list” reporting required because the URTI itself serves as the live ledger of all invoices. In other words, Ukraine doesn’t require a separate domestic listing of invoices to be sent monthly – the act of registering each invoice in URTI is the real-time reporting. Thus, the focus is on timely URTI registration and then periodic SAF-T for full accounting data. [rtcsuite.com] [rtcsuite.com], [rtcsuite.com]

Grace Periods and Transitional Measures

Phased Rollouts: Ukraine has generally introduced its mandates in phases rather than an abrupt switch, which serves as a de facto grace period for different groups of taxpayers. For example, the SAF-T requirement is phased: large companies in 2025, all companies by 2027. This gives smaller businesses extra time (~2 years) to adapt their systems before they are obligated to file SAF-T. Similarly, e-invoicing started with larger and VAT-registered firms and did not immediately force micro-businesses into VAT or e-invoicing. [edicomgroup.com]
No Ongoing “Soft Enforcement” Grace: Aside from the war-time relief discussed and scheduled phase-ins, there is no indefinite grace period for compliance – once a mandate is effective for a category of taxpayers, it is enforced. Ukraine expects full compliance from go-live dates (for instance, as of Jan 1, 2025 large taxpayers are expected to file SAF-T, not just test it). Companies were encouraged to adopt e-invoicing early (many did so voluntarily), but once it became mandatory, penalties have applied for non-compliance without any general “sandbox” period.
War and Emergency Provisions: The major grace periods granted have been tied to force majeure events. During the COVID-19 quarantine and the early phase of the 2022 war, Ukraine suspended most tax penalties and extended filing deadlines, including for e-invoice registrations. Specifically, invoices that fell due in the first months of the war (Feb–May 2022) were allowed to be registered by July 15, 2022 with no late fines. This was an extraordinary accommodation – effectively a grace period to cope with disruptions. After that date, normal rules (and fines) kicked back in. It’s worth noting the tax authority has been somewhat lenient if a taxpayer genuinely could not operate due to war (force majeure documentation might be required), but in general, as long as electronic systems are up, taxpayers are expected to use them. [tax.gov.ua], [tax.gov.ua] [tax.gov.ua]
Meaning of “Grace Period”: In the Ukrainian context, a grace period means a temporary relaxation of enforcement – either no penalties for late compliance or an extended deadline. The example above during martial law illustrates this: the law paused punitive sanctions for late e-invoice submissions for a period, then gave a concrete extension date after which penalties would apply again. Aside from such exceptional cases, businesses should assume that compliance dates are firm. When new regulations are passed, they often have future effective dates (like a law passed in 2021 for SAF-T starting 2025), which is effectively the lead time given to industry. Thereafter, missing the deadlines (for invoice reporting or SAF-T filing) will result in enforcement actions without further grace. [tax.gov.ua] [kpmg.com]

Penalties for Non-Compliance

Late Invoice Registration: Ukraine imposes monetary fines for late submission of e-invoices to the URTI. The penalty is typically a percentage of the VAT amount on the invoice, increasing with the length of delay. Under normal (pre-war) rules, failing to register an invoice on time could incur a fine of 10% of the VAT if the delay is up to 15 days, 20% if 16–30 days late, up to 50% of the VAT if over a year late. During the war, these fines have been temporarily reduced (e.g. 2% for short delays), but the stricter scale will return post-war. Even under the leniency, a 2% fine (capped at 1,020 UAH) is charged for any delay in registering zero-rated (0% VAT) invoices, emphasizing that every invoice must be timely registered. In practice, if a company consistently fails to register invoices, it not only faces cumulative fines but also risks being flagged by the tax authorities for audit or having its VAT operations restricted. [firstaccou…ing.com.ua] [spaceinvoices.com]
Failure to Register/Issue Invoices: Not reporting an invoice at all is a serious offense. The supplier who doesn’t register a required tax invoice can be fined (the graduated fines above eventually treat non-registration beyond a certain point as a 50% penalty). Moreover, the buyer loses the right to deduct VAT on that purchase if the invoice isn’t in the URTI. This creates a strong incentive on both sides to ensure invoices are reported. If a pattern of non-reported sales is detected, the tax authority can assess the VAT due and additional penalties (often 25% or more of the tax amount for underpayment) beyond the invoice-specific fines. In extreme cases, tax officials can also invalidate VAT credits and issue tax assessments for the missing documentation. [firstaccou…ing.com.ua] [vatcalc.com]
SAF-T Non-Compliance: For the SAF-T e-reporting, the law also defines penalties. Failing to submit the SAF-T file when required, or not adhering to the prescribed format/procedure, can lead to fines (exact amounts are specified in the Tax Code amendments). While the precise figures require reference to the Code, the guidance suggests penalties on the order of several thousand hryvnia for non-submission, escalating if not remedied. Given SAF-T is new, tax authorities have indicated they will enforce compliance – for instance, ignoring a request for a SAF-T file within 2 days could trigger a penalty and likely a more intense audit. Businesses are therefore expected to prepare systems to generate SAF-T to avoid these sanctions. [spaceinvoices.com]
Other Related Penalties: Ukraine’s tax law contains various other provisions: for example, failure to register as a VAT payer when required (e.g. a foreign digital service provider exceeding the threshold and not registering) can result in a significant fine (as noted earlier, 30 minimum wages). Also, submitting false data can lead to penalties or even criminal liability if it’s tax evasion. However, the core e-invoicing penalties to remember are the late registration fines. The State Tax Service has actively enforced these; courts have upheld that fines for late e-invoice registration are lawful even during challenging periods (unless a specific legal moratorium was in place). In summary, to avoid penalties, companies must: register all tax invoices within the allowed time frame, ensure completeness/accuracy to prevent rejection, and comply with SAF-T obligations as they phase in. The financial costs of non-compliance can add up quickly (for instance, a 15% penalty on a large VAT invoice is substantial), and non-compliance also endangers VAT recovery and invites audits, so the mandate is taken very seriously by businesses operating in Ukraine. [spaceinvoices.com] [tax.gov.ua], [tax.gov.ua]

Archiving Requirements and Retention Period

Archiving Obligation: Taxpayers must securely archive all electronic invoices and related tax documents for a specified retention period. Ukrainian law treats electronic invoices as “primary accounting documents,” so they fall under general record-keeping rules. Originally, the retention period was 3 years for tax invoices (as was common in Ukraine for many records). However, recent legislative changes have extended retention requirements. As of a law effective April 2023, most tax and accounting documents (including invoices, ledgers, filings) must now be kept for 5 years (1,825 days). This five-year retention aligns with the standard period within which the tax authorities can audit and issue assessments for VAT. [openenvoy.com] [dentons.com]
Format of Archiving: Invoices must be preserved in their original electronic form, complete with the digital signature and timestamp. Simply keeping paper printouts is not sufficient; the electronic format ensures that the audit trail (including the digital signature verifying authenticity) remains intact. Businesses typically store the XML invoice files and the electronic receipts from URTI in an audit-proof archive. The archive should safeguard the files’ integrity, accessibility, and readability for the full retention period. According to best practices, archived e-invoices should be kept on servers or cloud storage located in Ukraine (or accessible to Ukrainian tax auditors) and backed up to prevent loss. Companies are often required to provide these archived invoices to auditors in electronic form upon request. [easy-software.com], [easy-software.com]
Legal Requirements: The Tax Code and the Law on Accounting oblige companies to maintain these records in good order. The new 2023 law updated various retention durations: importantly, “primary documents… related to calculation and payment of taxes” must be kept for 5 years. This category unquestionably includes VAT invoices and SAF-T data files. (Certain records like transfer pricing documentation have a 7-year retention, but that’s a special case.) Non-compliance with document retention can lead to issues in audits – if, for example, a company cannot produce an invoice copy or SAF-T detail when asked, the tax authority could disallow the VAT credit or make adverse assumptions. During company liquidations, there is a procedure to hand important documents to a state archive, underlining how seriously document retention is taken. [dentons.com] [dentons.com], [dentons.com]
E-Archiving Practices: Archiving in electronic form is explicitly allowed and encouraged. Given that all invoices are already electronic, most companies use electronic archiving systems. The archived invoices must remain unchanged and accessible. It’s recommended to store them with indexes (by date, number, counterparty) to retrieve any invoice easily if needed. The URTI itself keeps a record of all registered invoices, but businesses should not rely on the tax authority’s database as their only archive – they are expected to have their own copies. In addition, any communications or receipts (for instance, URTI acceptance notifications) should be saved. In summary, Ukrainian companies must retain e-invoices and reports for 5 years in a secure, organized manner, and ensure those documents remain authentic (with digital signatures and metadata) and available for any future tax inspections. [openenvoy.com], [dentons.com]

Pre-Filled VAT Returns

No Pre-Populated Returns (Currently): Ukraine does not provide pre-filled VAT returns to taxpayers. Even though the tax authorities receive all invoice data in real time, the onus remains on the taxpayer to compile their VAT return each period and submit it through the electronic filing system. The VAT return (declaration) is a structured form where the taxpayer summarizes total taxable sales, total input VAT, adjustments, etc., for the month. Taxpayers must ensure these figures reconcile with the individual invoices in URTI and other records, but the tax authority doesn’t auto-compute it for you. Each registered VAT payer files a monthly VAT return by the 20th of the following month, using the prescribed form. This process is fully electronic, but it is not auto-generated by the government – the taxpayer (or their accounting software) prepares the return and submits it via the electronic cabinet or M.E.Doc system, etc. [leinonen.eu], [leinonen.eu] [leinonen.eu]
Cross-Checks vs. Prefill: While Ukraine doesn’t prefill your return, the State Tax Service does use the e-invoice data to cross-verify VAT declarations. For example, they will cross-check that the total sales declared by a taxpayer roughly match the sum of that taxpayer’s invoices in URTI for the month. They also match that one business’s reported purchase VAT corresponds to invoices issued by suppliers. Discrepancies (e.g., a buyer claiming input VAT for which the seller didn’t register an invoice) can trigger audits or automated notifications. In this sense, the e-invoice system indirectly enforces accurate returns. But unlike some countries (e.g., Italy or Spain) that have begun offering prefilled draft VAT returns using reported data, Ukraine has not yet implemented pre-populated VAT returns for taxpayers. Each business must manually (or with their own software) prepare the VAT return numbers and file the form.
Future Outlook: As of early 2026, there’s no announcement of Ukraine introducing prefilled VAT returns. The focus has been on “VAT in Digital” measures like e-invoicing and SAF-T. It’s conceivable that once SAF-T is fully implemented, the tax authority could have enough information to draft returns, but any such change would require new legislation. For now, taxpayers should assume they need to do the calculations and filing themselves. The VAT return form in Ukraine is detailed, requiring classification of sales by VAT rate and a breakdown of input VAT (with annexes listing adjustments, etc.), which the taxpayer completes based on their records. All the e-invoicing and e-reporting does not eliminate the filing of VAT returns; it simply ensures that what is filed can be verified against the source data. No part of the VAT return is prefilled by the tax authority – the taxpayer bears full responsibility for declaring the correct totals (and then the authority cross-checks after submission). In summary: there are no pre-populated VAT returns in Ukraine at this time – every VAT-registered business must submit its own return each month, despite the tax authorities already holding the invoice data. [leinonen.eu], [leinonen.eu]

References & Sources: Regulations and official resources underpinning the above information include: the Tax Code of Ukraine (which in Article 201 established the e-invoicing requirements and deadlines), various amendment laws (e.g., Law No. 1014-IX 2011 for e-invoices, Law No. 6255/2021 for SAF-T, Law No. 2260-IX and 2876-IX 2022–23 for wartime adjustments), and guidance from the State Tax Service (STS). The STS’s official website and press releases provide details on implementation and enforcement (for example, STS news confirming the resumption of URTI obligations and court rulings on fines). Practical summaries have been published by global consultancies and VAT specialists, such as VATupdate and Big-4 firms, which were used for the latest updates. Notably, the EDICOM and KPMG Ukraine reports outline the SAF-T timeline, and specialized providers like Spaceinvoices and Storecove have documented Ukraine’s e-invoicing scope and requirements in 2024 updates. For detailed reading, taxpayers can refer to the primary legislation (e.g., Tax Code Article 201 for tax invoices, Article 69 and transitional provisions for war-time rules, and the Ministry of Finance orders for SAF-T schema) as well as the State Tax Service’s official guidelines on e-invoicing (often found in the STS’s online knowledge base). These authoritative resources confirm that Ukraine’s e-invoicing and e-reporting regime is comprehensive and continuously evolving toward greater digital compliance. All businesses dealing with Ukraine must stay updated via these official channels to remain compliant. [knowledgen…or.pwc.com] [tax.gov.ua], [firstaccou…ing.com.ua] [spaceinvoices.com] [vatcalc.com] [tax.gov.ua] [edicomgroup.com], [kpmg.com] [spaceinvoices.com], [vatupdate.com] [kpmg.com] [vatupdate.com] [vatupdate.com]

See also

Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
Join the LinkedIn Group on ”VAT in the Digital Age” (VIDA), click HERE

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