QR Code Payments: Official Tax Service Clarification on Fiscal Registration

On November 28, 2025, the State Tax Service of Ukraine (Cherkasy region) published a crucial clarification regarding the use of cash registers (RRO) when accepting payments through QR codes. This decision has critical implications for Ukrainian entrepreneurs using modern cashless payment methods.

The Central Question: Is a Cash Register Required for QR Payments?

Many entrepreneurs have faced uncertainty about whether businesses are required to use fiscal cash registers (RRO) and/or software cash registers (PRRO) when selling goods or services paid for via QR codes. The Tax Service has provided a clear answer to this question.

Key Conclusions of the Clarification

QR Codes with IBAN: No Cash Register Required

The most important conclusion: businesses are NOT required to use RRO and/or PRRO when selling goods, works, or services paid for via QR codes that contain full bank account details in IBAN format.

This means that if your QR code contains:

  • Recipient's IBAN account
  • Recipient's name
  • Tax identification number
  • Payment purpose
  • Amount and currency

Then using a cash register is not mandatory.

Other Electronic Payment Methods: Cash Register Required

However, the Tax Service emphasizes that if QR code payments involve encoding payment details for any other electronic payment method (other than IBAN account details), the use of RRO and/or PRRO is mandatory.

Legal Basis for the Decision

The Tax Service clarification is based on several key legislative acts:

Cash Register Law

According to paragraph 1 of Article 3 of Law of Ukraine No. 265/95-VR "On the Use of Cash Register Recorders in Trade, Public Catering and Services," business entities are required to conduct payment transactions through RRO for cash and/or cashless transactions using electronic payment instruments.

However, the use of RRO depends not on the form of payment transactions, but on the method by which the business entity receives funds as payment for goods or services.

NBU Rules on QR Codes

According to the Rules for Formation and Use of QR Codes for Credit Transfers (Resolution of the NBU Board dated May 28, 2020 No. 68), a QR code is defined as a matrix code containing information about the recipient of funds, designed for quick and error-free transmission of money transfer transaction details.

Payment Services Law

According to Law of Ukraine No. 1591-IX "On Payment Services," an electronic payment instrument is a payment tool implemented on any medium that contains data in electronic form necessary for initiating a payment transaction.

Critically important: In terms of legislation regulating payment transactions, a QR code is not a payment instrument. It is merely a method of transmitting information for making a bank transfer.

Practical Significance for Business

This clarification opens new opportunities for Ukrainian entrepreneurs:

Equipment Cost Savings

The absence of a requirement to purchase, install, and maintain cash registers means significant cost savings, especially for small businesses and freelancers.

Ease of Use

QR payments with IBAN do not require complex integration with fiscal servers or staff training on cash register operations.

No Subscription Fees

Unlike RRO, which requires monthly maintenance, QR codes with IBAN do not generate ongoing costs.

Quick Implementation

Businesses can start accepting payments through QR codes immediately, without waiting for cash register registration with the tax service.

Who Benefits from This?

The Tax Service clarification is especially important for:

  • Small businesses and sole proprietors: ability to accept cashless payments without investment in cash register equipment
  • Online services: legal way to receive payments without fiscal registration
  • Charitable organizations: accepting donations becomes simpler and more transparent
  • B2B companies: invoicing and receiving payments without additional administrative costs
  • Service companies: accepting payment for services without the need to install RRO

Differences from Other Payment Methods

It's important to understand the difference between various cashless payment methods:

IBAN Transfers via QR (No RRO Required)

  • Direct bank transfer
  • Contains full account details
  • Processed by the banking system
  • Not a "payment transaction" in the sense of Law No. 265

Payment Cards and Terminals (RRO Required)

  • Use of payment cards
  • Operations through POS terminals
  • Considered payment transactions
  • Require fiscal registration

Electronic Wallets via QR (RRO Required)

  • QR codes for Apple Pay, Google Pay, etc.
  • Do not contain direct IBAN details
  • Subject to fiscal registration requirements

Technical Implementation of QR Payments with IBAN

To legally accept payments without RRO, a QR code must contain the following mandatory elements:

  1. IBAN account: full account number of the recipient in international format
  2. Recipient name: official name of the legal entity or full name of the sole proprietor
  3. Tax ID: tax identifier of the recipient
  4. Payment purpose: description of goods/services (up to 140 characters)
  5. Amount: exact payment amount
  6. Currency: currency code (UAH, USD, EUR)

This data is encoded according to NBU Rules No. 68 and ensures automatic filling of all details in the customer's banking app.

Benefits for Customers

The IBAN QR payment system benefits not only businesses but also customers:

  • Security: all payments go through official banking channels
  • Error-free: details are filled automatically, eliminating human error
  • Transparency: complete information about the recipient and payment purpose
  • Convenience: simply scan the code with a smartphone camera
  • No extra fees: no intermediaries needed, payment goes directly to the recipient

Compatibility with Banking Apps

QR codes that comply with NBU standards are supported by all major Ukrainian banks:

  • Monobank
  • PrivatBank
  • PUMB
  • Sense Bank (Alfa-Bank)
  • Oschadbank
  • Raiffeisen Bank
  • OTP Bank
  • UkrSibbank
  • and over 30 other banks

This ensures the method's universality for any customer regardless of their bank.

Implementation Recommendations

If you plan to start accepting payments through QR codes with IBAN:

  1. Verify the format: the QR code must contain IBAN details, not a link to a payment service. You can create a proper QR invoice at pmnt.app
  2. Save the clarification: keep a copy of the official Tax Service clarification in case of inspections
  3. Inform customers: explain to buyers how to use QR codes for payment
  4. Maintain records: even without RRO, it's necessary to keep accounting records of all transactions
  5. Use reliable services: choose verified solutions for QR code generation

The Future of QR Payments in Ukraine

The Tax Service clarification creates a favorable environment for the development of cashless payments in Ukraine. This is a step towards simplifying entrepreneurship and lowering barriers to business entry.

Expected outcomes:

  • Increase in the number of small entrepreneurs accepting cashless payments
  • Development of new fintech services for generating and processing QR invoices
  • Improvement in the culture of cashless payments among the population
  • Reduction in the shadow economy through the transparency of bank transfers

Conclusion

The official clarification from the State Tax Service dated November 28, 2025, removes important legal uncertainty and confirms: QR payments with IBAN details do not require the use of RRO or PRRO. This opens new opportunities for Ukrainian business, lowers barriers to accepting cashless payments, and stimulates the development of the fintech industry.

For entrepreneurs, this means a legal opportunity to accept payments without additional costs for cash register equipment, and for customers — a convenient, secure, and fast payment method.

Material prepared based on the official clarification of the Main Department of the State Tax Service in Cherkasy region dated November 28, 2025.