On 30 October 2026, the Ministry of Finance of Ukraine issued Order No. 247, amending the “Regulations on the Forms and Procedures for Primary Accounting Documentation” (originally approved by Order No. 1197 dated 28 December 2021). The amendments respond to the widespread adoption of electronic document management systems (EDMS) and the Diia.Business portal. Key changes include mandatory use of qualified electronic seals (QES) for all primary documents signed after 1 January 2027, standardized XML schemas for acts of acceptance (КС-2, КС-3), and new requirements for documenting war-related losses (damage/destruction of assets) under martial law. The Order also clarifies that scanned copies of paper originals certified by QES have full legal force, eliminating the need to retain physical archives for documents created after the effective date. Transition period: voluntary compliance from 1 November 2026; mandatory from 1 January 2027.
Key Takeaways
- Universal QES Requirement: Every primary document (invoices, acts, waybills, payroll sheets) signed electronically must bear a qualified electronic seal issued by an accredited key certification center (АКСК). Self-signed certificates (Diia.Sign for individuals) are insufficient for corporate entities; only organizational QES certificates are accepted.
- War Damage Documentation: New Form № WAR-1 “Act of Assessment of Damage/Loss of Assets Due to Military Actions” is introduced. It must be prepared by a commission including an independent certified appraiser, signed with QES, and submitted to the tax authority within 10 days of the event to support tax deductions for lost assets and VAT credit reversal exceptions.
- Archive Digitization Deadline: Companies must migrate existing paper archives (prior to 2027) to certified electronic storage (e.g., Diia.Archive or licensed EDMS providers) by 31 December 2028. Original paper documents may be destroyed only after successful verification of digital copies by the State Archival Service.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement