Do online stores need RRO?

All individual entrepreneurs in the 2-4 groups are required to use cash registers to issue fiscal receipts to customers by 2024. However, online store owners frequently have inquiries regarding the utilization of RROs and PRROs for online transactions. This article addresses the most commonly asked questions.

RRO for online stores: what does the law state?

In accordance with the provisions set forth in Law of Ukraine No. 265/95, a seller is obliged to utilize RRO or PRRO for the registration of payment transactions on the tax service’s server. Fiscalization through PPO/PRRO is required for both cash and the majority of non-cash payments. Accordingly, a cash register should be utilized for each payment transaction.

A settlement transaction is defined as the acceptance of cash, payment cards, payment checks, tokens, and so forth from the buyer at the point of sale of goods (services). It also encompasses the issuance of cash for goods returned by the buyer (unrendered service) and, when a bank payment card is used, the execution of the relevant settlement document for payment in non-cash form for goods (services) by the buyer’s bank. In the event of a return of goods (refusal of service), the settlement documents for the transfer of funds to the buyer’s bank are also executed.

Article 2 of the Law of Ukraine No. 265/95

From a legal standpoint, the essential elements of this definition are the existence of a transaction between the seller and the buyer, as well as the point of sale. While Law No. 265/95 does not define the concept of “point of sale”, it does define the place of settlement:

The term “place of settlement” refers to the location where settlements are made with the buyer for the goods or services provided, as well as the location where the buyer receives prepaid goods or services.

Article 2 of the Law of Ukraine No. 265/95

Accordingly, in the event that the buyer pays for and receives the goods in one location, this is indicative of a settlement transaction. In all such cases, the seller is required to use RRO or PRRO.

In particular, a cash register is required in cases where the seller:

• accepts payment in cash;
• sends goods through postal services;
• accepts payment for goods through acquiring services such as LiqPay or WayForPay;
• receives non-cash payment via QR code;
• or transfers the goods to the buyer via a courier who accepts payment.

In accordance with Law of Ukraine No. 265/95, the seller is required to issue a receipt to the buyer following each payment transaction. In the event that the seller is using a post or courier service, a fiscal receipt is also required. This is further clarified on the State Tax Service’s official website.

When purchasing goods through an online store and making payments for them using a payment card, provided that such goods are delivered by post or courier service, a business entity is required to issue a payment document of the established form (a receipt from the RRO) and a duly executed warranty card.

In the event that a third-party courier service is utilized for the delivery of goods, it is the responsibility of the sender to transfer ownership of the goods to the service. The service representative is required to issue a payment document to the consumer for the total purchase price, including the cost of delivery.

State Tax Service of Ukraine

In what cases online stores do not need RRO?

Online stores may not use cash registers if they accept payments only in non-cash form. In particular, when the buyer makes a payment for the goods:

• by transfer using the IBAN number; through the bank’s cash desk;
• by transferring funds to the current account of the online store;
• through a self-service bank terminal;
• or via a QR code that routes to the online store’s current account.

In the current online trading environment, a number of business models are in use (dropshipping, cash on delivery, etc.). To determine whether RRO or PRRO is required in such cases, it is essential to consider the payment method for the goods and the party responsible for accepting it.

Dropshipping

In regards to dropshipping, the tax authorities advise adhering to the general rule whereby the party that accepts payment for the goods is responsible for issuing the fiscal receipt.

In the event that funds are received by a seller who has ordered goods from a supplier, the seller is required to utilize the RRO/PRRO. The fiscal receipt must be placed in the box with the goods.

Cash on delivery

In the event that an online store accepts payment for goods on a cash-on-delivery basis to a current account, a cash register is also a necessary component. However, market practice indicates that most payments are typically received by a postal service operator (Nova Poshta, Ukrposhta etc.). In such cases, it is important to consider the status granted to the operator by the State Tax Service.

In particular, in Individual Tax Consultation No. 2263 (hereinafter “ITC No. 2263”), the tax authorities have classified Nova Poshta as a forwarder. When sending goods via Nova Poshta, the seller is required to use an RRO/PRRO.

It is the responsibility of the seller to generate a fiscal cash receipt before sending goods via a freight forwarder (logistics company). This receipt must be placed in the box with the goods.

Clarification of the State Tax Service dated 11.08.2023

Ukrposhta, as defined by ITC 2263, is classified as a courier (carrier). It accepts cash on delivery on its own behalf, eliminating the need for the seller to use a cash register:

As outlined in contracts offered to business entities by couriers (carriers), the use of RRO/PRRO by the seller of goods is not mandatory. This is because the courier accepts cash on delivery from the recipients of the shipment on its own behalf and issues a settlement document upon acceptance directly when the shipment is transferred to the buyer.

Clarification of the State Tax Service dated 11.08.2023

Software registrars of settlement operations for online stores

The law permits sellers to utilize either hardware cash registers (RROs) or software cash registers (PRROs). Each of these types is suitable for different business needs. An RRO is typically utilized for trade at the point of sale, whereas a PRRO is well-suited for online trading.

PRRO enables online stores to utilize a variety of delivery options (in-store pickup, postal services, courier delivery, etc.). The seller will issue an electronic receipt to the buyer via email or other messaging platforms. If required, the document can be printed and sent with the goods.

PRRO is also ideal for selling goods on marketplaces. The software registrar can be seamlessly integrated with the cash register, eliminating the need for additional equipment to achieve high-quality work. The software cash register is designed to automatically exchange data with the State Tax Service server, thereby generating tax reports.

PRRO providers offer services tailored to specific business areas. For instance, Vchasno.Kasa presents additional opportunities for online retailers. The software cash register can be registered online, so you can start issuing receipts on the same day.

PRRO can be connected to any payment terminal. The Vchasno.Kasa service enables entrepreneurs to keep track of goods and issue receipts for advance payments.