Is a cash register required in 2026 for payments via IBAN, QR, LiqPay, NovaPay and Monobank
Do you need an RRO in 2026 when paying via IBAN, QR code, Monobank, LiqPay, NovaPay or WayForPay – this is one of the most common questions for sole proprietors and online businesses. Many entrepreneurs mistakenly believe that any cashless payment allows them to operate without a receipt. Some fiscalize everything – and significantly overpay where it is legally possible not to use RRO/PRRO. Others think that cashless payment automatically exempts them from issuing a receipt – and receive fines from 100 to 150% of the sale amount.
We break down each specific payment method: IBAN, QR code, LiqPay, NovaPay, WayForPay, Portmone, Monobank, Privat24 – and explain all the pitfalls of working with RRO/PRRO.
Is an RRO required for cashless payments in 2026
When an RRO/PRRO is required is a question entrepreneurs often get wrong: most look at the name of the service rather than the nature of the transaction. “I use LiqPay – so I need it”, “payment to IBAN – so I don’t need it”. But Article 3 of Law No. 265 links the obligation to fiscalize not to the name of the payment instrument, but to whether the payment is a settlement transaction.
What is a settlement transaction?
A settlement transaction is the acceptance of cash, payment cards from a customer, or issuing a settlement document for cashless payments. If your payment falls under this definition, an RRO/PRRO may be required. But there are exceptions, and this is where the biggest confusion lies.
At first glance, everything seems simple, but these are exactly the types of payments where entrepreneurs most often make mistakes. It is easy to confuse a standard bank transfer to IBAN with a payment via a payment service or non-bank institution, fail to understand when it is necessary to check the source of funds, or assume that any payment to IBAN is automatically safe.
When an RRO is required in 2026: table by payment methods
| Payment method | RRO/PRRO |
|---|---|
| Transfer to IBAN via bank | Often no |
| Transfer to IBAN via non-bank service | Often yes |
| QR code to IBAN | Often no |
| QR code to checkout / card | Often yes |
| LiqPay / WayForPay / Portmone | Depends on what is sold and how the payment is processed |
| POS terminal / acquiring | Usually yes |
| Monobank transfer to IBAN | Often no |
| Monobank checkout / installment | Requires individual analysis |
Important: the final conclusion depends on the specific payment model, source of funds and type of goods or services.
Penalties for not using an RRO in 2026
For failure to use an RRO/PRRO, the financial penalty is 100% of the value of goods, works or services sold in violation for the first offense and 150% for each subsequent one. It must be paid within 10 days.
Important: The tax authority requires the seller to independently determine the source of each cashless payment and fiscalize everything that does not fall under the exceptions. And ignorance is never an excuse.
Therefore, before building a payment acceptance model, it is important to understand where the line lies between “when an RRO is not required” and “when an RRO is mandatory”. This is exactly why a payment acceptance model audit exists – to be sure there will be no issues during an inspection. Now we will review the most common payment scenarios and explain when fiscalization is required and when it is not.
Payments to IBAN and online banking: when you can operate without an RRO
Payments to IBAN without an RRO is the most common question among entrepreneurs who accept cashless payments. The safest scenario is this: the customer receives the seller’s bank details and independently transfers funds to a current account in IBAN format via their bank. This is a classic banking transaction if the payment is made from one current account to another through a bank. In this model, an RRO/PRRO is not required.
Online banking systems include:
- Privat24,
- Oschad24/7
- Sense SuperApp
- Monobank
- and other similar services.
So, for example, an RRO is not required when paying via Monobank to IBAN. Because this is a banking transaction, not internet acquiring. The key indicator:
the customer in their banking app independently selects an account and enters the recipient’s details – IBAN and code.
But there is a non-obvious trap here that causes problems for entrepreneurs:
not every IBAN account automatically gives the right not to use an RRO/PRRO.
The point is that you need to look not only at the account number format but also at the nature of the transaction. That is, if the funds came not from a bank but from a payment account of a non-bank institution – for example, Nova Pay, or through a terminal or system that does not have a banking license – an RRO/PRRO becomes mandatory.
Therefore, the formula “IBAN = no RRO” is a dangerous simplification. A more accurate approach is:
a bank transfer without an RRO/PRRO is legal only when the funds are received specifically from a bank account through a banking transaction – and not via checkout, a payment link, or another card payment tool.
Is an RRO required for installment payments through a bank
Installment payments via Monobank or PrivatBank are a popular model, but with a hidden risk. The result – fines for transactions that seemed completely safe.
And this nuance is the transit account 2924. This is a technical bank account through which card payments and acquiring are processed. If installment payments actually go through it, for the tax authority it looks like a settlement transaction, and an RRO/PRRO becomes mandatory.
Simple example: a client arranged an installment through Monobank. In this case, the payment comes to you not as a direct transfer, but through the bank’s card infrastructure. And there is a risk that the funds passed through account 2924. In such a case, it is safer to fiscalize the payment.
Advice from our accountants: if you are not sure through which account your payments are coming – check your bank statement. If it includes account 2924 or other signs that the payment went through card/acquiring infrastructure, it is safer to verify the payment model with your bank or accountant and, if necessary, fiscalize the transaction. Otherwise, you will have to prove to the tax authority yourself that it is not acquiring.
Do you accept installment payments via Monobank or PrivatBank – and are not sure whether a receipt is required?
Contact the accountants at buh.ua. We will review your situation and show you how to operate safely.
Payment via QR code: when an RRO is required and when it is not
RRO when paying via QR code is a topic where one detail decides everything: what exactly is encoded inside. And this detail separates “no RRO needed” from “RRO required”.
The point is that a QR code itself is not a payment method. For fiscalization, what matters is not where the QR code leads, but how the funds are ultimately received. There are two options here.
Option 1. When a QR code does not require an RRO/PRRO
If the QR code contains the full bank account details of the seller in IBAN format – then an RRO is not required. In this case, the QR code only simplifies the transfer of details for payment. Essentially, this is the same scenario as a regular payment using IBAN details.
Option 2. When a QR code already requires an RRO/PRRO
If the QR code contains details of another electronic payment method – different from a bank IBAN – in most cases, fiscalization becomes mandatory. The simplest example: the QR leads to payment services such as LiqPay. The same logic applies as with standard card payments – this is already a settlement transaction that requires an RRO/PRRO.
Therefore, a QR code is just a form, and it does not matter. For RRO/PRRO, the essence of the transfer is what matters. The mistake here is costly: if an entrepreneur daily accepts payments via a QR code that leads to acquiring and does not fiscalize them, this is not just a single underpayment. It is a systematic violation, for which fines for not using an RRO are предусмотрены – and you can avoid them only in cases defined by law. And such violations are the easiest for the tax authority to detect during inspections, as the movement of funds is visible in the bank statement.
Payments via LiqPay, WayForPay, Portmone: when an RRO is required
RRO when paying via LiqPay, WayForPay or Portmone is also a question without a universal answer. The NBU classifies these as money transfer services. And everything depends on what you are selling.
Is an RRO required for online sales of goods
When selling goods online via payment cards, acquiring or payment services, an RRO/PRRO is usually required. If payment is made exclusively via a classic bank transfer to IBAN without payment services, the situation must be assessed separately.
Is an RRO required for online sales of services
If you sell services, the situation is different. Fiscalization does not apply to payments for services carried out exclusively through money transfer services.
If you sell both goods and services
If your business combines both goods and services – the rule is the same. Payments for services can be non-fiscalized, while payments for goods must обязательно be fiscalized.
And to avoid using an RRO at all when selling services, the client must pay via IBAN through their bank, not through a “payment button” on your website.
So the question is not whether you use LiqPay or Portmone. The question is what you sell to your customers. And note: all payment systems have different conditions for using an RRO. Therefore, before connecting them, read the comparison of payment systems in Ukraine in 2026.
Typical mistakes of sole proprietors when working with RRO/PRRO
Typical mistakes with RRO/PRRO arise not because of the complexity of the law, but due to incorrect qualification of the payment. And each of them – we remind you – can cost a fine from 100 to 150% of the transaction amount.
- Errors in receipt details. If mandatory details are incorrectly specified in the receipt, in particular the address of the business unit, this may create a risk of claims during an inspection. This is especially relevant for sole proprietors who use their home address for PRRO: the data in the receipt must match the data submitted in form 20-OPP.
The address in PRRO must exactly match the address you specified in form 20-OPP. If in 20-OPP it says ‘office 5’, but in the receipt it says ‘apt. 5’ or just the house number – the receipt is considered to contain an error in the details.
- Forgetting to close the shift. If the shift lasts more than 24 hours – this is already a risk. Or another situation: the shift was opened, but receipts were not registered. Fines are usually not imposed for this, but it is already a reason for a tax audit. To avoid this mistake – set up automatic shift closing in Checkbox.
- Not keeping inventory records when selling high-risk goods. If your assortment includes jewelry, medicines, or technically complex household goods – inventory accounting is mandatory for all goods, even if there is only one risky item. The fine is up to 100% of the value of unaccounted goods.
- Not issuing receipts for payments via Nova Pay. One of the most common mistakes. Entrepreneurs believe that if the client paid “to IBAN” – no receipt is needed. But if the funds were received via Nova Pay or a non-bank self-service terminal – fiscalization is mandatory in most typical scenarios.
- Not fiscalizing acquiring. POS terminal, payment via link, tap-to-phone, QR code with a card – all of this requires a fiscal receipt. If a client pays by card in any form – a receipt is usually required.
- Relying only on the type of service. The fact that the payment went through LiqPay, Portmone or WayForPay does not determine anything by itself. You need to analyze the specific payment scenario – how exactly the client made the payment.
- Assuming that a QR code allows you not to use an RRO. What matters is not the QR code itself, but what is encoded in it: IBAN bank details – no RRO required, card number or another electronic payment method – RRO required.
- Ignoring the difference between goods and services. The exception for payments via online banking systems and money transfer services applies only to services. When selling goods – fiscalization is mandatory regardless of the payment method.
FAQ: most common questions about working with RRO/PRRO
Is an RRO/PRRO required if the client simply transfers money to IBAN?
It depends on who provides the transfer service. The IBAN format itself does not guarantee that an RRO/PRRO is not required. What matters is whether it is a bank current account and whether the funds were received as part of a banking transaction or via a non-bank payment service provider, such as NovaPay. In the latter case, fiscalization is mandatory.
Do I need to check where each payment came from?
Yes. For RRO/PRRO, the source of cashless payments matters: funds can come either from banking infrastructure or through a non-bank payment service – and this determines whether fiscalization is required.
If a customer pays via Privat24, Oschad24/7 or another online banking service, is an RRO/PRRO not required?
Partially. Only if the customer makes a direct transfer to your IBAN account via such a service. If it is not a bank transfer by details but another payment model, an RRO may be required. For example, installment payments.
When does a QR code not require an RRO/PRRO?
When it encodes the full bank account details of the seller in IBAN format. In this case, the QR code simply facilitates a bank transfer.
If a client pays via Monobank, is it a regular banking transaction without RRO/PRRO?
No. If it is a direct transfer to IBAN via a banking app – an RRO is not required. But if a payment link, checkout, or another card payment tool is used – it is a different model.
Is it possible to operate without RRO/PRRO for cashless payments?
Yes, but not always. If it is a classic bank transfer to IBAN without payment services, an RRO/PRRO is often not required. If the payment goes through a card, checkout, payment link or non-bank service, fiscalization may be required.
Conclusion
RRO/PRRO for cashless payments is a complex topic with non-obvious nuances. Many factors matter here: where the funds came from, what exactly you are selling, and how the payment is technically processed. Entrepreneurs most often make mistakes in these details – and the cost of the mistake is clear: a fine of 100% of the sale amount for the first violation and 150% for repeated ones.
If you are not sure how your payments are classified – do not wait for an inspection. A consultation or audit of your payment acceptance model will help identify risks in advance – and set up your processes so that there are no questions from either the bank or the tax authority.
Want to set up payment acceptance correctly from the start?
Our accountants support sole proprietors from start to finish – and manage fiscalization. So that RRO/PRRO fines do not catch you off guard.
