Ukraine Liberalizes Business Documentation Processes

Following the general trend of business deregulation, the Ukrainian Parliament has adopted legislative changes aimed at easing formal requirements to documenting business transactions. By Law No. 4791-IX dated February 24, 2026, which is set to take effect on April 1, 2026, the Parliament amended the existing Law of Ukraine “On Accounting and Financial Reporting in Ukraine” No. 996-XIV dated July 16, 1999 (as amended) and made unnecessary the traditional delivery-acceptance act under most services contracts.

It should be noted that Ukraine has always been notorious for applying an excessively formalistic approach to documenting business operations. Frequently, even an ordinary transaction, such as the provision of services, may require, besides a respective contract and invoice, a number of other contractual documents to be regularly executed by the parties.

One of such documents is the so-called “delivery-acceptance act” (or “act of transfer and acceptance”). In addition to the invoice, it is widely used in Ukrainian accounting practice for the purpose of confirming the actual provision of services under a services contract, their corresponding value (service fee charged) and any expenses incurred by the contractor. Notably, the Ukrainian Tax Office also places great value on delivery-acceptance acts during its tax audits of local businesses as proof of the genuine character of transactions conducted by them and to substantiate transaction-related income and expenses of their parties.

Despite being a popular accounting tool in local business practice, the delivery-acceptance act has been negatively viewed, especially by foreign counterparties of Ukrainian businesses, as creating an unnecessary additional burden in contractual relations. As a rule, the contractor (services provider) has to prepare and sign two counterparts of a delivery-acceptance act in certain intervals (e.g., monthly, quarterly, semi-annually, annually), after which it is provided to the customer (services recipient). If the latter accepts the services/deliverables rendered in the covered period and specified in the act, it shall countersign both counterparts thereof and return one of them to the contractor.

In overseas jurisdictions, the contractor’s invoice is generally sufficient and accepted for both payment and accounting purposes, while delivery-acceptance acts are unknown there. Consequently, Ukrainian companies often have to spend a lot of time in order to explain to their foreign counterparties the purpose of these documents and the procedure of their execution. On top of that, depending on the actual volume of services transactions, the administration of delivery-acceptance acts by accounting/financial departments on both sides (including their preparation, execution, review, approval, signing, postal delivery, etc.) may require considerable managerial efforts in terms of both time and financial expenses.

The recent legislative amendments are meant to address these issues. Pursuant to them, primary accounting documents issued by the contractor or lessor under a services or lease contract no longer require for their validity the signature of the counterparty, i.e., the customer or lessee, respectively. At the same time, in order to benefit from this provision, the following conditions have to be met:

1) A respective services or lease contract shall be executed in writing and explicitly provide for such procedure of documenting business transactions that are based on the contract (i.e., by including an express statement that the customer’s (lessee’s) signature on contractual documents is not required).

2) Respective contractual documents must contain the date (period) of services provision or a lease period as well as all other mandatory elements of a primary accounting document (the name of the document, its date of issuance, the issuing party (contractor or lessor), a description of the transaction (its content, quantity, etc.), the name and position of a person responsible for the transaction as well as such person’s signature).

3) The covered transactions shall be reflected in accounting records in the period when they are actually undertaken.

In practical terms, the key consequence of the amendments outlined above is that, by abolishing the requirement of the customer’s (lessee’s) signature, the traditionally used delivery-acceptance act is rendered obsolete for services and lease contracts, provided that the contracts themselves expressly stipulate this option. Therefore, an invoice properly issued and signed by the contractor containing all mandatory elements shall be deemed sufficient for payment purposes as well as for confirming the real character of the transaction it underlies and the related income and expenses of the parties. Herewith, the previously mentioned burden of administering delivery-acceptance acts, first of all, on the part of (foreign) customers (who had to review, approve, countersign them and return one specimen to the contractor), is eliminated, and the process of documenting respective business transactions will become substantially easier.

However, for certain types of transactions, the requirement of signing transaction-related documents by both parties remains intact. Hence, the parties to such transactions must continue to use mutually signed delivery-acceptance acts, which can be explained by specifics of these transactions. They include:

1) Transactions financed by utilizing public funds.

2) Transactions related to leases of state or municipal property.

3) Contracts for the performance of construction, design and survey works.

4) Agreements regarding donations, charitable contributions, and humanitarian aid.

In conclusion, the discussed legislative changes will significantly liberalize traditional business administration processes, reduce existing transaction-related document flows and generally help optimize commercial relations in the services sector both in the domestic and cross-border context. Nevertheless, proper document management should remain a priority for Ukrainian businesses, given the strictly formalistic approach still applied by most Ukrainian authorities, in particular, the Tax Office and courts.

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This publication is for informational purposes only. If you would like to learn more or seek legal advice, please contact one of the following or your usual Nobles contact:

Alexander Weigelt (Partner), Denis Vergeles (Counsel).