Ukraine E Invoicing | SEA VAT, URTI & EU Integration Pilots - Integra International

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E-invoicing in Ukraine in 2026

February 19, 2026

Author:
Iegor Sinitsyn
EBS (Emergex Outsourcing LLC), Partner, Tax & TP practice leader
E: [email protected]

Tetiana Lutsko,
EBS (Emergex Outsourcing LLC), Head of TP group
E: [email protected]

Edited by:
Integra International
Grant Gilmour, B.Sc., MBA, CA, CPA Canada, BC, CPA USA, Az, GDipICL.Sc.
INTEGRA TAX WORLD NEWSLETTER EDITOR
E: [email protected]

 

E-invoicing in USA in 2026

Ukraine is at early stages of the process of implementing e-invoicing. There is currently no officially approved roadmap for the full-scale implementation of e-invoicing

From a top level the E-invoicing implementation roadmap is

  1. The recognition of electronic documents as legally equivalent to paper documents
  2. Increasing adoption of e-documents and EDI services
  3. Adoption of a common standard
    1. Harmonize current standards for e-invoicing and data exchange, and ensure legal implementation and compliance
    2. Develop and adopt the necessary legal instruments to enable the application of standardized e-invoicing.
  4. Building internal infrastructure enabling integration with international e-invoicing networks (e.g., Peppol)
  5. The introduction of mandatory use of e-invoicing
    1. Phase implementation:
      1. B2G (public procurement)
      2. B2B (business)
      3. B2C (customers)
  6. Development of dedicated apps (VAT-reporting, custom clearance etc.)

 

Current developments

  1. Electronic Tax Invoices
    1. SEA VAT system in place since 2015
    2. Tax invoices submitted electronically via e-Cabinet or software
    3. Not classical e-invoicing, but a VAT-specific local model
  2. Electronic Document Interchange (EDI)
    1. Widespread use of EDI systems (M.E.Doc, SOTA, Vchasno, etc.)
    2. Used for invoices, contracts, delivery notes
    3. Decentralized, non-unified, and optional
  3. Digital Government Reporting
    1. Tax and accounting reports submitted-digitally
    2. Submitting via Diia and Taxpayer’s e-Cabinet

 

Local reporting standards

  • Set by State Tax Service, Ministry of Finance, and State Statistics Service
  • Support ERP integration via APIs
  • Tax invoices use fixed XML templates
  • Other documents (invoices, acts) can be flexible but must follow EDM requirements
  • Documents sent via electronic operators or Taxpayer’s E-Cabinet with qualified electronic signature (QES) (valid only in Ukraine)
  • Tax invoices must be registered in the Unified Register of Tax Invoices within 15 days (VAT payers)
  • Harmonization with European standards (Peppol, UBL) planned but not yet implemented

 

E-invoicing & tax audits

Already in place

  • Tax office analyzes data from the Unified Register of Tax Invoices (URTI) to select companies for audit
  • E-invoices help detect suspicious activities
  • Late or missing registration may lead to fines up to 50% of VAT

What’s Expected

  • Fewer on-site audits, more automated checks
  • Growth in e-audits and risk scoring (e.g. SAF-T UA)
  • Faster error correction required from accountants
  • Fewer mistakes, easier interaction with STS
  • More real-time transaction monitoring

 

Domestic law

System of Electronic Administration of VAT

  • VAT-registered businesses are required to issue and register tax invoices (B2B, B2G, B2C)
  • Registration is done through the SEA VAT system and the Unified Register of Tax Invoices (URTI)
  • Invoices must be registered within 15 calendar days from the date of issue
  • Applies to both sales to VAT payers and certain transactions with non-payers or for internal use
  • Tax invoice registration is carried out within the taxpayer’s VAT registration limit
  • Penalty for non-registration of tax invoice:
    • Up to 15 days late → 10% of VAT amount
      16–30 days late →    20% of VAT amount
      31–60 days →            30% of VAT amount
      61–90 days →            40% of VAT amount
      Over 90 days →        50% of VAT amount

 

VAT Registration Limit in SEA VAT

ΣLimit = ΣPaymentsIn + ΣVATReceived + ΣAuditAdjustments + ΣVoluntaryTopUps
– ΣVATIssued – ΣVATRefunded – ΣOtherAdjustments

Symbol Description
ΣLimit Registration limit (maximum VAT amount allowed for E-invoice registration)
ΣPaymentsIn Funds credited to the taxpayer’s VAT account (from sales, customers, etc.)
ΣVATReceived VAT from incoming tax invoices (from suppliers, registered in the system)
ΣAuditAdjustments VAT amount charged during tax audits (e.g., understated liabilities)
ΣVoluntaryTopUps Voluntary payments made by the taxpayer to their VAT account
ΣVATIssued VAT from issued tax invoices and adjustments registered by the taxpayer
ΣVATRefunded Amount of VAT refunded from the budget
ΣOtherAdjustments Other deductions or corrections (e.g., funds returned from the VAT account)

 

Ukraine’s Pilot Projects with Peppol, UBL & EU Standards

  1. Peppol / eDelivery Pilot (EU4Digital)
    1. Since Oct 2020, Ukraine has piloted cross-border e-invoicing with Poland via Peppol network
    2. Format: Peppol BIS Billing 3.0, protocol AS4
    3. Pilots with Armenia, and Moldova
  2. Readiness for EU Standards
    1. Ukraine has adopted the full base of EU standards via national standardization bodies (e.g. CEN, CENELEC)
    2. Alignment underway with UBL / EN 16931, particularly under the Peppol ViDA initiative
  3. Legal & Technical EU Integration
    1. Pilot projects on mutual recognition of Qualified Electronic Signatures (QES) with EU & Eastern Partnership
    2. Ukraine involved in EU Digital Identity Wallet initiatives, working toward cross-border digital ID compatibility

Disclaimer

This communication contains general information only based on collective research. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No representations, warranties or undertakings (express or implied) are given as to the accuracy or completeness of the information in this communication, and none of EBS (Emergex Outsourcing LLC), Integra International, related entities, employees or agents shall be liable or responsible for any loss or damage whatsoever arising directly or indirectly in connection with any person relying on this communication.=

EBS (Emergex Outsourcing LLC) and Integra International, and their related entities, are legally separate and independent entities.

© 2026 Integra and EBS (Emergex Outsourcing LLC)

About the Author:


Iegor Sinitsyn:

Iegor is experienced auditor and consultant on tax issues, accounting and management reporting. He has professional experience in the tax accounting analysis, preparation of documentation and transfer pricing reports, provision of advice on Ukrainian and international taxation, preparation and analysis of tax reports and declarations. Over 12 years of professional experience, Iegor has carried out comprehensive tax diagnostics for more than 100 companies.

 


Tetiana Lutsko:

Specialist in Transfer pricing

Has experience in conducting documentary audits for legal entities, incl. on issues of transfer pricing.

Tatiana has been working at EBS since November 2017, successfully using her previous experience in preparing transfer pricing documentation for clients.

About EBS (Emergex Outsourcing LLC):

EBS is a multiservice provider that has been assisting businesses and organizations in Ukraine for over 27 years, providing constant support and professional resolution of any operational tasks, enabling them to work efficiently and develop.

Integra International Bio: 

https://integra-international.net/find-an-integra-firm/find-firm-profile/name/emergex-outsourcing-llc/

Basswood Counsel:

https://www.ebskyiv.com/en/