Acts Without the Client's Signature: What Law No. 4791-IX Actually Changes

Since 1 April 2026, a Ukrainian service provider can close out a job with a document that only it has signed. Law of Ukraine No. 4791-IX of 24 February 2026 added a single paragraph to Article 9 of the Accounting Law, and that paragraph does something narrow but genuinely useful: the absence of the customer's signature on a primary document is no longer a defect in that document.

The change is widely described as "acts of completed work have been abolished". They have not. What was abolished is the requirement that the customer sign one. The document itself — with its date, its content, its volume, and the provider's own signature — is as mandatory as it was before.

What the Law Actually Says

The full title is "On Amending Article 9 of the Law of Ukraine 'On Accounting and Financial Reporting in Ukraine' Regarding the Simplification of Preparing Primary Documents for the Provision of Services". It was adopted on 24 February 2026, signed by the President on 16 March, published in Holos Ukrainy on 17 March, and took effect from the first day of the month following publication — 1 April 2026.

Mechanically, it inserts one new paragraph after paragraph seven of Article 9(2) of Law No. 996-XIV of 16 July 1999, and renumbers the former paragraphs eight through eleven as nine through twelve. Here is the operative text:

If a primary document contains information on the date (period) of the provision of services, performance of works, or hire (lease), then the absence of the requisites specified in paragraphs six and seven of this part on the part of the customer of the services (works) or the hirer (lessee) is not a violation of the requirements for preparing a primary document, provided that such a procedure for documenting business operations is provided for by a contract concluded in written form, and such business operations are recorded in accounting in the period in which they were carried out. The provisions of this paragraph do not extend to requirements for documenting business operations paid for out of public funds; business operations carried out under contracts of hire (lease) of state or municipal property; construction contracts and design and survey works; contracts of donation, charitable or humanitarian aid.

The Ukrainian original, as consolidated into Article 9(2) of Law No. 996-XIV:

«Якщо первинний документ містить інформацію про дату (період) надання послуг, виконання робіт або найму (оренди), то відсутність передбачених абзацами шостим і сьомим цієї частини реквізитів із сторони замовника послуг (робіт) або наймача (орендаря) не є порушенням вимог до оформлення первинного документа, за умови що такий порядок документування господарських операцій передбачено договором, укладеним у письмовій формі, і такі господарські операції відображаються у бухгалтерському обліку в періоді їх здійснення.»

Everything the law does is in that sentence. It is worth reading it before reading anyone's summary of it, because the summaries drift.

What Is Dropped, and What Is Not

Article 9(2) of Law No. 996-XIV lists six mandatory requisites of a primary document. The new paragraph waives two of them — and only on the customer's side.

The provider's own responsible person and signature stay exactly where they were. So does the requirement to describe what was supplied and how much of it. A unilateral act is still a formal primary document — it is not a chat message with a number in it.

The Three Conditions the Statute Imposes

Read as a checklist, the paragraph imposes three cumulative conditions. All three must hold; failing any one puts you back under the ordinary two-signature rule.

1. The document states the date or period of the services, works, or lease. Not the issue date — the service date or period. "Services provided from 1 to 31 July 2026" satisfies this; "Invoice dated 31 July 2026" does not.
2. A written contract provides for this documentation procedure. The contract, not an email exchange after the fact. Note that Article 205(1) of the Civil Code treats written and electronic form as the same category ("orally or in written (electronic) form"), so an accepted public offer published online is a written contract for this purpose.
3. The operation is recorded in accounting in the period in which it was carried out. This mirrors Article 9(5) of the same law, which already required exactly that. The new paragraph makes the general rule a condition of the concession: date the document to the period the work actually happened in, and book it there.

What the Law Does Not Require

Most published templates and compliance checklists present a "deemed accepted unless the client objects within N days" clause as a statutory condition of the new rule. It is not. The statute asks only that the procedure for documenting the operation be set out in a written contract. There is no objection window in the text, no minimum period, and no prescribed wording.

You should nevertheless write that clause, for a reason worth understanding, because it explains what the new law can and cannot do for you:

• Accounting law governs the form of the document. Law No. 4791-IX tells the tax authority that a one-sided document is properly executed.
• Civil law governs whether the service was accepted. That is a separate question, and Law No. 4791-IX says nothing about it.

Article 205(3) of the Civil Code is the anchor: "In cases established by contract or law, a party's will to enter into a legal act may be expressed by its silence." Silence counts as acceptance only where your contract says it does. Without that clause you have a validly formed accounting document that your client is still free to dispute on the merits. With it, the client's silence for the agreed number of days is itself the acceptance — and Article 627 of the Civil Code (freedom of contract) is what lets you agree it.

That is the practical division of labour: the statute fixes your bookkeeping, and your contract fixes your position in a dispute. Both are worth having; only one of them is new.

Where the New Rule Does Not Apply

The second sentence of the paragraph carves out four categories, and they are absolute. In these cases a signed, bilateral act remains necessary:

• operations paid for out of public funds;
• operations under contracts of hire (lease) of state or municipal property;
• construction contracts and design and survey works;
• contracts of donation, charitable or humanitarian aid.

If you invoice a state body, a municipal enterprise, or a communal-property landlord, or if you work in construction or design, the new paragraph does not reach your contract at all. This exclusion list is missing from a good deal of the practical guidance published about the law — check it before you rewrite your templates.

A Clause That Does the Job

Contracts with Ukrainian counterparties are written in Ukrainian, so here is workable wording in that language:

Первинні документи. Сторони погодили, що акт наданих послуг (виконаних робіт) складається Виконавцем в односторонньому порядку та містить період надання послуг (виконання робіт). Виконавець направляє акт Замовнику на адресу електронної пошти, зазначену в реквізитах Договору. Акт вважається прийнятим Замовником без зауважень, якщо протягом 5 (п'яти) робочих днів з дати направлення Замовник не надав Виконавцю письмових вмотивованих заперечень. Господарська операція відображається сторонами в обліку в періоді її фактичного здійснення.

Four things that clause has to nail down:

• The unilateral procedure itself. This is the only element the statute actually demands.
• The delivery channel. Email, messenger, or a link to the invoice — name it, and name the address. An objection period cannot run from a delivery you cannot evidence.
• The objection window. Five to ten business days is the range most practitioners suggest. Pick one and apply it consistently.
• The service period and the accounting period. Conditions 1 and 3 of the statute, restated as a contractual obligation on both sides.

This is a starting point rather than a finished legal document. Adapt it to your line of work, and have a lawyer read it before it goes into a contract you will sign a hundred times.

Does This Help a Sole Proprietor?

Indirectly, and that distinction matters. Article 2 of Law No. 996-XIV extends the Accounting Law to legal entities — a Ukrainian sole proprietor (FOP) does not keep double-entry bookkeeping and is not the addressee of Article 9. So the new paragraph does not, strictly speaking, relieve a FOP of anything.

What it changes is the position of the party on the other side of your invoice:

• Your corporate client's problem becomes solvable. Their accountant needed your countersigned act to book the expense. The clause in your contract is what now lets them book it from a document you signed alone — which is to say, it is what stops your invoice from sitting unpaid while a signature is chased.
• The Tax Code still applies to you. Paragraph 44.1 requires taxpayers to keep records of income and expenses on the basis of primary documents, and prohibits reporting figures that documents do not support. Your own records need a paper trail regardless of who signs.
• Retention periods are unchanged. Under paragraph 44.3, primary documents must be kept for at least 1,095 days in the general case, and 1,825 days for corporate income tax payers, counted from the day the relevant return was filed.

The Invoice as the Document

There was already a route to closing a service without an act, and it is worth knowing because it still works alongside the new one.

In its letter of 16 February 2017 No. 31-11410-06-5/4339, the Ministry of Finance took the position that a properly drawn invoice can itself be the basis for recording a supply of goods, works, or services in accounting without a separate handover act — on the condition that it has been paid, with the payment evidenced by a payment order, a bank statement, a receipt, or similar, and that the invoice carries requisites identifying the operation and its parties.

Law No. 4791-IX adds a second route with a different trigger:

The State Tax Service, commenting on the new law, has framed it the same way: the law does not cancel primary documents or remove oversight, but where the parties have agreed it, an invoice signed by the provider may be used instead of an act of completed work.

What Did Not Change

Four things are routinely assumed to have moved with this law, and none of them did.

• VAT timing. Under paragraph 187.1 of the Tax Code, the tax liability on services arises on the earlier of two events: funds arriving in the supplier's account, or the drawing up of the document certifying that the service was supplied. A unilateral act dated 31 July fixes that date at 31 July. The new rule removes a signature; it does not give you latitude to date documents conveniently.
• Fiscalization. Whether a sale requires an RRO or software RRO is decided by how the money is received, not by how the closing document is signed. The two questions are independent — as they were before 1 April 2026.
• The obligation to have a document at all. The tax service has been explicit on this point. Something has to exist, dated, describing what was supplied and in what volume.
• Your client's right to disagree. A one-sided act is properly formed, not automatically true. If the client says the work was not done, the dispute proceeds on the evidence, which is precisely why the objection clause and your supporting materials — briefs, correspondence, reports, timesheets — are worth keeping.

Where a QR Invoice Fits

pmnt.app issues payment requests, not accounting documents: the QR code is how the money moves, and your invoice or act is what closes the operation in the books. The two do intersect at one useful point, though.

The payment purpose that travels inside an NBU-standard QR code is free text, and pmnt.app allows up to 420 characters of it. That is more than enough room for the service period the statute's first condition demands — "Consulting services, 1–31 July 2026, invoice #123" — which means the same period appears in the document you issue and in the payer's bank statement. When you later reconcile, the bank record and the primary document agree on which period the money belongs to, which is the third condition restated in a form an auditor can check.

Because payment is an ordinary IBAN transfer rather than card acquiring, the payment side of the transaction also stays outside the fiscalization question entirely — but that is a separate regime, and it neither helps nor hinders anything Law No. 4791-IX does.

Checklist Before You Rely on This

1. Your written contract or public offer contains a clause on unilateral primary documents.
2. The clause names the delivery channel and the objection period.
3. Your act or invoice states the period of service, not only its issue date.
4. The document is dated to, and booked in, the period the work actually occurred.
5. The document still carries all four surviving requisites and your own signature.
6. Your contract is not in one of the four excluded categories.
7. Documents are retained for at least 1,095 days (1,825 for corporate income tax payers).

Conclusion

Law No. 4791-IX is a one-paragraph amendment, and its scope is exactly one paragraph wide: the customer's signature and job title may be missing from a document that shows the service period, where a written contract says so and the operation is booked in the right period. It does not abolish acts, does not touch VAT timing, does not reach public funds or construction, and does not decide whether a service was actually accepted.

That is still a real change. Chasing a countersigned act across weeks was a genuine cost for every service business in Ukraine, and from 1 April 2026 a single well-drafted contract clause removes it. The work is in the clause — write it once, check it against the exclusion list, and make sure the service period is on every document you issue.

This is an explanatory article, not legal or tax advice. Have your own accountant or tax adviser confirm how the rule applies to your contracts.