Exemption from RRO Fines for Sole Proprietors (FOP) in 2026: Who Is Eligible and How to Confirm

The author of the article: Denis Korablyov

Modified date: 15 February 2026

In 2026, sole proprietors (FOPs) are exempt from fines for violations of the law on RRO if they operate in temporarily occupied territories, territories of active or potential hostilities in accordance with the Order of the Ministry of Reintegration No. 309, except for trade in excisable goods.

FOPs have almost no so-called “benefits” left – most were canceled or suspended during martial law. But the key word here is “almost”. Who is the lucky one who may not install a cash register and avoid a fine? Maybe you are among them?

What Is Exemption from RRO Fines

Let’s start with the main point: there is no exemption from the obligation to use an RRO as such.

If a FOP is legally required to use a cash register (a traditional RRO or a software PRRO), they must use it. This is not up for discussion.

However, in some cases when a FOP violates this requirement, there is an exemption from fines for failure to use cash registers, as well as for other violations of the RRO law – for example, failure to keep inventory records.

Important: If you trade in excisable goods (alcohol, tobacco, fuel), no exemptions from fines apply to you!

Real case: an entrepreneur wrote to us: “My mother sells at the market in Kharkiv, of course she does not have a cash register. Will there already be a fine? How will they check? Will the tax office come to the market or what?”

The answer to this question depends on where exactly you conduct business. Not where your FOP is registered, but where the activity is actually carried out.

Three Categories of Territories Where Exemption from RRO Fines Applies

Let’s open the Law of Ukraine “On the Use of Payment Transaction Recorders in the Sphere of Trade, Public Catering and Services”. We move to the final provisions, paragraph 14, which states a very important point:

Starting from October 1, 2023, business entities are exempt from liability for violations of the requirements of this law committed in the following territories:

1. Temporarily occupied territories

2. Territories of active hostilities

3. Territories of potential hostilities

Important nuance: The list of these territories is constantly updated. Martial law is ongoing, and the situation changes. Today your city may be on the list, and tomorrow – not. Therefore, the relevance of the status should be checked regularly.

We will explain how to do this at the end of the article.

Place of Registration vs Place of Activity: Where FOPs Often Make Mistakes

This is a crucial point. For exemption from fines, the tax authority is interested not in your registered address, but in the actual place of business activity.

Online Trade and Exemption from RRO Fines

We have clarified offline trade. But what if you sell online or provide services remotely?

Here the logic of the State Tax Service is somewhat more complex. The tax authority insists: the right to exemption depends on where the goods are physically shipped from.

• If you are in Kharkiv: You sell online and ship orders from a post office branch in Kharkiv – you are exempt from fines.
• If you are a dropshipper: Your FOP may be registered in Kharkiv, but if the goods are shipped to the customer from a warehouse in Lviv – fines will apply. The place of activity is considered the shipping point.

The tax authority states: a FOP has the right to exemption from fines if online business activities are carried out from a locality included in one of the three territory lists.

The key word here is “shipment”. Wherever the goods are physically shipped from – that location is considered the place of business activity for online trade.

Important nuance: If you receive payment not directly to your IBAN account (for example, through payment systems, cards, cash), but intermediaries or payment services transfer funds to your account, then:

• You fiscalize income from the remuneration (your commission), not from the cost of the goods
• You issue a receipt in accordance with the Law of Ukraine

If you fail to do this – fines are guaranteed.

How to Obtain a Guaranteed Exemption: Individual Tax Consultation (ITC)

Now about the most important point. What we have described in this article is not explicitly stated in the RRO law.

This is the position of the State Tax Service of Ukraine, which they provide in response to requests for individual tax consultations (ITC).

How does it work?

1. A FOP submits a request to the State Tax Service of Ukraine for an ITC
2. In the request, they describe their situation in detail:
   • where they are registered
   • where they conduct business activity
   • where the goods are shipped from
   • what documents they have
3. The State Tax Service of Ukraine provides a specific response: “Yes, based on how everything is described in your request, your FOP is exempt from fines for violations of the RRO law”

Why is this necessary?

If you want a 100% guarantee of exemption from fines in your case, you should submit a request to the State Tax Service of Ukraine for an individual tax consultation on this matter.

This way, you will receive an ITC specifically for your FOP and thus be officially exempt from fines.

You should also be prepared for the fact that the tax authority sometimes provides so-called “formal replies”. These are responses that simply quote legal provisions without giving a clear conclusion regarding your situation (“yes” or “no”).

How to avoid a “formal reply”?

1. Do not write “am I entitled to the benefit?”. Instead write: “I ship goods through Nova Poshta branch No. 1 in Kharkiv, which is confirmed by waybills. Am I exempt from a fine for not using a PRRO in accordance with paragraph 14 of the Final Provisions of the Law?”.
2. Attach to the request a copy of the extract from the Single Tax register and Form 20-OPP.
3. If you receive an ambiguous response, you have the right to challenge such an ITC in court in order to require the tax authority to provide a specific clarification.

Where to Check the Official List of Territories

The official list of territories is contained in the Order of the Ministry for Reintegration of the Temporarily Occupied Territories of Ukraine No. 309 (and related acts).

Tip: Search not only by the name of the city, but also by the name of your territorial community. If the community as a whole is included in the list – all settlements within it fall under the exemption conditions.