Is a PRRO/RRO required for Group 1 sole proprietors in 2026: current requirements

From January 1, 2026, new requirements for the mandatory acceptance of electronic payments will come into force in Ukraine. Resolution No. 894 of the Cabinet of Ministers of Ukraine obliges all entrepreneurs to ensure the possibility of payment by card, through mobile applications, or other electronic payment instruments.

In this regard, two key questions are increasingly being asked: what changes await businesses in 2026, and will Group 1 sole proprietors need a PRRO after the new rules are implemented? Let’s take a closer look.

New requirements for cashless payments in 2026

CMU Resolution No. 894 establishes clear rules: from now on, every entrepreneur, regardless of their field of activity or taxation system, is required to ensure the ability to accept electronic payments.

This can be payment by bank card through a POS terminal, payment through mobile payment services, or other modern electronic tools that allow you to transfer funds quickly and conveniently.

It is important to note that businesses can no longer refuse to accept card payments from customers. At the same time, cash payments are not being abolished: entrepreneurs are simply expanding the list of available options, giving buyers the freedom to choose how they want to pay for goods or services.

Provision of services and sale of goods: is there a difference?

The same rules for accepting electronic payments apply to all entrepreneurs, regardless of whether they are engaged in trade or services.

Therefore, the requirement to be able to accept cashless payments also applies to Group 1 sole proprietors who are engaged in the following:

• Retail trade in markets — sale of goods from market stalls without the use of hired employees.
• Provision of consumer services to the population — services included in the official List of Consumer Services: repair of clothing, footwear, watches, hairdressing services, photography services, repair of household appliances, etc.

⚠️ Exception: business in a war zone

The legislation takes into account the real conditions in which entrepreneurs operate during a full-scale war. Therefore, special exceptions regarding the mandatory acceptance of electronic payments are provided for sole proprietors operating in the most affected regions.

The obligation to provide cashless payment options does not apply to sole proprietors in Group 1 if they operate in areas that are:

• officially included in combat zones;
• under temporary occupation;
• surrounded or blockaded, where normal business activity is impossible.

The current list of such territories is approved in List No. 376, which is regularly updated taking into account the situation on the front line.

The exemption is valid:

• for as long as the community remains in a zone of combat, occupation, or blockade;
• for an additional three months after the end of active combat operations or de-occupation, to give entrepreneurs
• the opportunity to resume work, establish communications, and set up the necessary infrastructure.

In practice, this means that sole proprietors in these areas may temporarily operate without POS terminals and not accept electronic payments until the transition period has ended. In this way, the state is providing a flexible approach and support for businesses in conditions where full operation is objectively difficult.

Why are Group 1 sole proprietors no longer exempt from the rules?

Until 2026, Group 1 sole proprietors were not required to accept card payments or other electronic payment methods. The tax authority explained this by saying that Group 1 consists of the smallest entrepreneurs, who work without employees and have limited annual income. The state took into account the specifics of their activities: sales in markets, small retail trade, or household services, which were traditionally carried out in cash.

In 2022, the government adopted Resolution No. 894, which began to gradually expand the circle of entrepreneurs required to provide cashless payment options. Group 1 sole proprietors were temporarily excluded from the new rules to give businesses time to adapt and make the tech more accessible.

Starting in 2026, this exception will be scrapped: the government wants to make sure everyone’s on the same page.

Do sole proprietors in Group 1 need to use cash registers/payment terminals in 2026?

Despite the fact that from 2026 all entrepreneurs must provide cashless payment options, cash registers/payment terminals remain optional for group 1 sole proprietors. The requirement to install a POS terminal or other means of accepting electronic payments does not affect the use of cash registers in any way.

This exemption is clearly enshrined in legislation: paragraph 296.10 of the Tax Code of Ukraine and paragraph 6 of Article 9 of Law No. 265/95-VR exempt single tax payers in group 1 from the obligation to use cash registers and payment terminals, regardless of the method of payment.

In 2026, the rules for sole proprietors in group 1 will indeed change, but these updates do not create additional pressure on entrepreneurs. They are required to do only one thing: ensure the possibility of cashless payments, as other categories of businesses have been doing for a long time.