Electronic Primary Documents: Which Electronic Documents Must Be Reflected in Accounting

Accountants working in a digital environment process hundreds of documents every day: invoices, acts, delivery notes, and correspondence with counterparties. One question arises most often: which documents qualify as primary documents and can serve as a basis for accounting entries, and which are auxiliary or informational?

Confusion in terminology often leads to unnecessary work — duplicating documents on paper «just in case.» However, as of 2026, Ukrainian legislation clearly defines the status of electronic primary documents, as well as the requirements for their execution and storage.

In this article, we will examine how to identify electronic primary documents, avoid duplicate work, and reliably protect your company from risks during audits.

What Is a Primary Document in 2026?

According to Article 9 of the Law of Ukraine «On Accounting and Financial Reporting in Ukraine», a primary document is a document that contains information about a business transaction.

A business transaction is not merely an agreement, but an action that results in real changes in assets, liabilities, or equity of an enterprise (Article 1 of Law No. 996-XIV).

The following types of primary documents can be distinguished as confirming the fact of a business transaction:

If a business transaction has actually occurred but is not supported by a properly executed primary document, the controlling authority may question the expenses related to such a transaction. As a result, the basis for recognizing VAT input credit is lost, and there is a risk of additional corporate income tax assessments.

Which Documents Are Not Primary?

In accounting practice, it is essential to distinguish documents that do not record the fact of a business transaction and therefore cannot serve as a basis for accounting entries. The most common include:

• Invoice (bill). Typically, this is only a proposal to pay for goods or services, not confirmation of supply. An invoice becomes a primary document only if it contains all mandatory requisites defined by Ukrainian law and explicitly states that it confirms the provision of services or receipt of goods. It must also be signed by the parties or paid.
• Contract. A written agreement between business partners. It defines the terms of supply but does not confirm that goods or services have actually been delivered.
• Price list / Commercial offer. Informational materials reflecting potential pricing, but not confirming an actual transaction.
• Reconciliation statement. A document confirming the status of settlements at a specific date. It merely summarizes data already recorded in accounting and is not a basis for recognizing assets or liabilities.

Mandatory Requisites of a Primary Document

For a document to have legal force, it must contain the requisites defined in Part 2 of Article 9 of the Accounting Law. Depending on the nature of the transaction, additional (non-mandatory) requisites may also be included.

Electronic Form of Primary Documents: What Is Considered the Original?

According to Article 7 of the Law of Ukraine «On Electronic Documents and Electronic Document Flow», the original of an electronic document is the electronic version containing mandatory requisites and an electronic signature of the responsible person.

To distinguish between an original and a copy of an electronic primary document, follow these principles:

• Original is a file with an electronic signature. Only a file created and stored in electronic document management systems has full legal force.
• Copy is a printed version. A paper copy must be duly certified but does not replace the original file during an audit.

A common mistake: accountants sign a paper document, scan it, and send it to a counterparty. However, a scan is merely a digital copy of a paper document. Without the original paper version with a handwritten signature, the scan has no legal force in a tax audit or in court.

Other typical situations are summarized below:

Common Mistakes That Invalidate a Document

Even with a valid QES, a document may lose its status as a primary document if it contains errors, such as:

• Incorrect company name — prevents identification of the transaction party.
• Missing units of measurement — makes it impossible to determine the transaction volume.
• Mismatch of periods — for example, an act dated March covering services for January without contractual clarification, violating the accrual principle.
• Signature by an unauthorized person — if the signer’s authority is not valid (e.g., expired power of attorney), the document loses evidentiary value.

How to Confirm the Validity of Electronic Primary Documents During a Tax Audit

Business practice shows that companies successfully pass audits by the State Tax Service using electronic documents. For tax authorities, the key factor is not the format, but the presence of mandatory requisites and proper documentation of the transaction.

The procedure for submitting documents during a tax audit is defined by Ministry of Finance Order No. 1393. Electronic documents, along with an inventory, may be submitted via email or on digital media (e.g., a flash drive).

After submission, the tax authority:

• decrypts the documents and verifies them against the inventory;
• checks the integrity of the QES;
• sends confirmation of receipt to the taxpayer.

In the Vchasno.ODE service, all documents are stored in a convenient archive, allowing instant retrieval during audits.

Checklist for Verifying Documents Before Accounting Entry

Before recording a document in your accounting system, verify:

• Signature status (QES): whether it was valid at the time of signing;
• Authority: whether the signer is authorized to sign financial documents;
• Integrity: whether the file has been altered after signing.

Modern electronic document management systems, such as Vchasno.ODE, automate these checks, preventing the signing or sending of documents with missing fields or invalid certificates — thus eliminating part of the risks and routine before the document even enters accounting.