QR Code Payments and Fiscal Registration: When РРО is Required and When It Isn't

Direct bank transfers via IBAN QR codes do not require РРО (fiscal cash register) registration in Ukraine—a significant distinction from acquiring-based QR payments that fundamentally changes compliance obligations for businesses using services like pmnt.app.

The State Tax Service of Ukraine has repeatedly confirmed that the payment destination, not the QR code itself, determines fiscal requirements. When customers scan a QR code containing IBAN bank details and complete a standard bank transfer, no fiscal receipt is required. However, when QR codes redirect to payment gateways like LiqPay or Fondy where card details are entered, full fiscalization becomes mandatory with penalties reaching 150% of transaction value for violations.

The Fundamental Principle: How Funds Arrive Matters

Ukrainian tax authorities have established a clear legal framework separating different QR payment types. The key insight from official DPS clarifications: a QR code is not a payment instrument under settlement operation legislation. The code merely transmits information—what happens next determines the legal treatment.

Account code classification from the State Tax Service provides concrete guidance. Current account IBAN transfers (code 2600) do not require РРО. Bank terminals (code 2920) do not require РРО. However, non-bank financial institutions like Fondy or WayForPay (code 2650) and transit accounts for payment cards (code 2924) do require full fiscal registration.

This classification system offers businesses a practical test: examine where funds actually land and how they get there.

IBAN-Based QR Payments Operate Outside Settlement Operations

When a customer scans a pmnt.app QR code, their banking application opens with pre-filled transfer details—IBAN number, recipient name, tax ID, and payment purpose. The customer then authorizes a standard bank transfer from their own account. No payment card is involved, no acquiring intermediary processes the transaction, and no "electronic payment instrument" is used in the legal sense.

The DPS confirmed this interpretation explicitly: when selling goods or services where payment is made using a QR code containing full IBAN bank account details, the business is not obligated to use РРО or ПРРО.

This means businesses can legally accept payments without РРО/ПРРО by using only IBAN-based QR invoices. Services like pmnt.app generate these codes following NBU Resolution № 68 standards, creating what the law treats as facilitating ordinary bank transfers rather than conducting settlement operations.

Practical verification for any QR code: scan it and examine the contents. If you see only "UA" followed by 27 characters (the IBAN format)—no РРО required. If you see a card number, payment page link, or redirect to LiqPay/Fondy—РРО mandatory.

Merchant Acquiring Through QR Codes Triggers Full Fiscal Obligations

The regulatory treatment changes completely when QR codes redirect customers to payment processing pages. LiqPay, Fondy, WayForPay, Portmone, and similar services operate as acquirers—the customer enters card details, the payment network processes the transaction, and funds route through the acquiring company before reaching the merchant's account.

This constitutes a "settlement operation" under Law № 265/95-ВР because an electronic payment instrument (the customer's card) is used, the transaction occurs "at the point of sale" in the legal sense, an intermediary acquirer processes the payment, and the merchant initiates a charge request rather than receiving a payer-initiated transfer.

Merchants using acquiring-based QR payments must register РРО or ПРРО (software fiscal register), issue fiscal receipts for every transaction, and since March 1, 2025, ensure receipts contain QR codes linking to the DPS verification system per Ministry of Finance Orders № 601 and № 674.

Mixed Payment Methods Require Nuanced Compliance

Many businesses accept both IBAN transfers and card payments. The DPS clarifies this scenario: a ФОП accepting both IBAN transfers and Fondy payments must have РРО registered, but fiscal receipts are issued only for Fondy transactions. Direct IBAN receipts are not settlement operations and do not pass through the РРО system.

This creates an important compliance pathway: businesses needing to offer multiple payment options can segregate their obligations, fiscalizing only the acquiring transactions while treating IBAN receipts as standard bank transfers.

Penalties for Non-Compliance Have Returned to Full Severity

The temporary reduced penalty regime for individual entrepreneurs (ФОП) ended on July 31, 2025. Current fine structure under Article 17 of Law № 265/95-ВР:

• Not using РРО when required: 100% of transaction value (first offense), 150% (repeat offenses)
• Not issuing fiscal receipt: 100% (first), 150% (repeat)
• Operating with expired РРО service: 100% (first), 150% (repeat)

Critical detail: each individual transaction without proper fiscalization counts as a separate violation. During a single inspection, the first discovered violation incurs 100%, but every subsequent violation—potentially dozens or hundreds—incurs 150% each.

Administrative penalties add further exposure: 850 грн for using unregistered РРО or not using РРО when required, 510 грн for failing to submit Z-reports.

The Special Case of Distance Services

Article 14 of the Law on РРО creates an exemption for businesses providing exclusively remote services that meet all three conditions: never accept cash, receive payment only through distance channels (including QR codes), and sell services, not goods.

Such businesses may avoid РРО even when using acquiring payment methods. However, this exemption doesn't apply to goods sales under any circumstances, and the tax authority interprets "services" narrowly.

How pmnt.app Fits the Regulatory Framework

Services generating IBAN-based QR invoices occupy a clearly defined regulatory space. When pmnt.app creates a QR code containing a merchant's IBAN, recipient name, tax ID, and payment details, it's facilitating what Ukrainian law treats as a standard bank transfer—the same operation as manually typing account details into mobile banking.

Key advantages of this model:

• No РРО registration required for these payments
• Zero acquiring commission (versus 2-3% for card processing)
• Funds arrive directly to the merchant's bank account
• Transactions settle same-day or instantly via SEP system
• NBU requires all banks to support IBAN QR codes

Limitations to understand:

• QR codes don't satisfy the requirement to provide POS terminal capability per CMU Resolution № 894
• Customer must have a Ukrainian bank account with mobile banking
• Some customers may prefer card payments for convenience or rewards

Key Regulatory Sources

The legal framework rests on several interconnected documents:

Primary legislation includes Law of Ukraine № 265/95-ВР "On Application of Registrators of Settlement Operations," Law of Ukraine № 1591-IX "On Payment Services" (30.06.2021), and Tax Code of Ukraine Article 296.10 regarding ФОП 1st group exemption.

NBU regulations include Resolution № 68 (28.05.2020) establishing QR code standards for credit transfers and Resolution № 11 (01.02.2021) updating QR code format requirements.

Government implementation documents include CMU Resolution № 894 (29.07.2022) on mandatory cashless payment capability and Ministry of Finance Orders № 601 and № 674 on fiscal receipt requirements.

DPS clarifications confirming IBAN exemption include letters dated 07.06.2024 № 3112/ІПК/99-00-07-04-01, 04.02.2025 № 528/ІПК, and 07.01.2025 № 48/ІПК, along with regional DPS communications from Kyiv, Ivano-Frankivsk, and Lviv oblasts.

Conclusion

Ukrainian businesses can structure their payment acceptance to minimize or eliminate РРО requirements by understanding the fundamental distinction between payment types. IBAN-based QR codes like those generated by pmnt.app represent bank transfers that fall outside the settlement operation definition—no fiscal registration required, no receipts to issue, no acquiring commissions to pay.

Acquiring-based QR payments through LiqPay, Fondy, and similar services trigger full fiscal compliance obligations with severe penalties for non-compliance. The 100%/150% fine structure makes proper classification of payment methods a significant financial risk management issue.

For businesses evaluating their payment infrastructure, the choice isn't simply about convenience or commission rates—it's about fundamentally different regulatory treatment based on how money moves from customer to merchant. The QR code is just the messenger; the destination determines the rules.