Unannounced on-site tax inspection in Ukraine: what a business should do

An on-site (in Ukrainian terminology, “factual”) tax inspection differs from most other control measures in that tax officers may arrive without prior notice — directly at a shop, restaurant, office, warehouse, salon, production site or any other place where business is actually carried on.

In practice such an inspection often begins with a test purchase. An officer of the State Tax Service of Ukraine (STS) may first buy goods or order a service as an ordinary customer, check whether a fiscal receipt is issued, and only then present their official documents.

In this situation, the first actions of the director, administrator, cashier or another employee can significantly affect the consequences for the business.

According to STS data, in the first seven months of 2026 tax audit units carried out more than 17,400 on-site inspections. As a result, almost UAH 298 million was paid to the budget and almost 1,700 unregistered workers were identified. The most frequent findings were sales without cash registers (RRO) or software cash registers (PRRO), breaches of inventory accounting, the use of unregistered workers and breaches of the rules for selling excise goods.

Below we look at when the STS is entitled to carry out an on-site inspection, which documents the inspectors must show, and how a business should act during such a visit.

What an on-site tax inspection is

Under subparagraph 75.1.3 of the Tax Code of Ukraine, an on-site (factual) inspection is one carried out:

at the place where the business is actually conducted;
at the location of business facilities;
at the location of other property of the taxpayer.

Unlike a documentary audit, the officers come directly to the place where the business sells goods, provides services, stores products or uses hired labour.

The subject of an on-site inspection may include:

the procedure for sales transactions;
the use of RRO or PRRO;
the issue of fiscal receipts;
cash handling;
the circulation of cash;
licences and other permits;
the production and circulation of excise goods;
inventory accounting;
the formalisation of employment relationships;
working-time records and payment of wages.

That is why on-site inspections most often concern retail, food service, hotels, salons, medical centres, online shops, the automotive business, petrol stations, and producers and sellers of excise goods.

Must the tax service give advance notice?

No.

Paragraph 80.1 of the Tax Code of Ukraine expressly provides that an on-site inspection is carried out without notifying the taxpayer.

This means that a company or a sole proprietor (FOP) may learn about the inspection only when the inspectors appear at the business premises.

The absence of notice is not in itself a breach by the STS.

At the same time, an inspection cannot take place simply because inspectors decided to visit a particular business. There must be grounds provided by law and a properly issued order.

Grounds for an on-site inspection

The main grounds are set out in paragraph 80.2 of the Tax Code of Ukraine.

An on-site inspection may be carried out, in particular, if:

an inspection of another taxpayer revealed information about possible violations by your business;
the STS received information from a state authority or local government body;
a buyer or consumer filed a written complaint, formalised as required by law, about a breach of the procedure for sales or cash transactions, patenting or licensing — for example, failure to issue a receipt;
mandatory reports on the use of RRO/PRRO were not filed or were filed with zero figures;
there is information about breaches of the rules for producing, storing, transporting or selling alcohol, tobacco products, e-cigarette liquids, fuel or other excise goods;
a previous inspection established a violation and the STS is checking whether it has been remedied;
information was received about the use of unregistered labour;
there is information that wages are paid without paying taxes;
an individual is carrying on business without state registration.

The inspection order must state a specific ground provided by the Tax Code.

A formal reference merely to Article 80 of the Tax Code without clearly identifying the statutory ground may be insufficient. However, the lawfulness of the order and the possibility of refusing admission must be assessed case by case, preferably with a tax lawyer.

Test purchase before documents are shown

Before an on-site inspection of sales and cash transactions begins, STS officers may carry out a test purchase (a “control sales transaction” under paragraph 80.4 of the Tax Code).

In effect, the inspector may act as an ordinary customer:

buy goods or order a service;
pay in cash or by card;
check whether the RRO/PRRO was used;
receive or not receive a fiscal receipt;
record the details of the document issued;
only then announce the start of the inspection.

Therefore, asking an employee to work out immediately whether a customer is a tax officer achieves nothing in practice.

Protection for the business lies not in spotting the test purchase, but in making sure that all sales are always processed in accordance with the rules.

Which documents the officers must present

Before an on-site inspection starts, STS officials must present or provide the documents required by Article 81 of the Tax Code.

1. Inspection assignment (napravlennia)

The assignment must state:

the date of issue;
the name of the tax authority;
the details of the order;
the name and details of the taxpayer or the inspected facility;
the address of the facility;
the purpose of the inspection;
the type of inspection;
the ground;
the start date;
the duration;
the position and surname of each inspector.

The assignment must be signed by an authorised official of the tax authority and bear its seal.

2. Copy of the inspection order

The order must state:

the date of issue;
the tax authority;
the details of the taxpayer or facility;
the address of the facility, if the inspection is not carried out at the tax address;
the purpose;
the type of inspection;
the statutory ground;
the start date;
the duration;
the period of activity to be inspected.

The order must be signed by the head of the tax authority, their deputy or another authorised person and bear the seal.

3. Official ID cards

The ID cards must belong to the very persons named in the assignment.

If another official tries to join the inspection, their authority must also be properly confirmed.

Failure to present these documents, or documents drawn up in breach of Article 81 of the Tax Code, may be grounds for refusing admission to the inspection. Refusal on any other grounds is not allowed.

Who may receive documents from the tax service

If the director, the FOP or the owner is not on site, this does not necessarily stop the inspection.

Under paragraph 80.2 of the Tax Code, a copy of the order is handed over against signature before the inspection starts to:

the taxpayer;
their authorised representative;
persons who actually carry out sales transactions.

So the documents may be handed to a cashier, sales assistant, administrator or any other employee who actually takes payments.

That is why every shop or other business facility should have an internal instruction for visits by the authorities.

What to do in the first minutes of an inspection

Step 1. Do not create physical obstacles

Do not:

lock the premises;
block the entrance;
switch off the cash register;
hide goods;
delete information from computers;
remove documents;
provoke a conflict with the inspectors.

Such actions will not stop the inspection, but may create additional evidence against the business.

Step 2. Notify management and a lawyer immediately

The employee who first deals with the inspectors should immediately notify:

the director;
the owner or the FOP;
the accountant;
the in-house or external lawyer;
the person responsible for the facility.

Ideally, employees should have a pre-agreed emergency legal support number.

Step 3. Check the inspectors’ identities

Compare the official ID cards with the assignment.

Check:

full name;
position;
STS body;
validity of the ID card;
that each person is named in the assignment.

Record the details of all officials present.

Step 4. Obtain and keep a copy of the order

Do not settle for a quick glance at the document.

Obtain a copy of the order and keep it for subsequent legal analysis.

It is also advisable to record:

the assignment;
the official ID cards;
the date and exact time the inspectors arrived;
the moment documents were handed over;
the names of employees present;
any actions taken before the documents were presented.

Step 5. Check the details in the documents

Pay particular attention to:

the correct company name or the FOP’s full name;
the EDRPOU code or taxpayer number;
the address of the facility;
the type of inspection;
the ground;
the subject;
the period under inspection;
the start date;
the duration;
the list of inspectors;
the signature and seal.

A mistake in the address, a mismatch of the facility, an inspector missing from the assignment, or an improperly issued order may be legally significant.

Step 6. Appoint one person to communicate

Do not allow all employees to explain the company’s business to the inspectors at once.

Appoint one responsible person who:

receives the requests;
hands over documents;
keeps track of the subject of the inspection;
keeps an internal record;
stays in contact with the lawyer.

Other employees should not argue, speculate or try to explain things they do not know for certain.

Can the business refuse to admit the inspectors?

Refusing admission is not possible in every situation.

Article 81 of the Tax Code provides that the grounds for refusal may be:

failure to present the required documents;
failure to provide a copy of the order;
no official ID card;
documents drawn up in breach of the established requirements.

Refusal on any other grounds is not allowed.

For example, the mere fact that:

the director is not on site;
the accountant is on leave;
the lawyer has not yet arrived;
the employee did not know about the inspection,

is not an automatic ground for refusing admission.

Before refusing, assess not only the formal defect but also the possible consequences.

If the business refuses admission, the STS draws up a report. If the inspection had lawful grounds, refusal of admission may lead to an administrative arrest of the taxpayer’s property (Article 94 of the Tax Code). In 2026 this risk is borne out by the practice of both the tax authorities and the administrative courts.

That is why a decision to refuse admission should be made only after an urgent consultation with a lawyer who has checked the order and the assignment.

What the tax service checks

The scope depends on the subject stated in the order.

RRO and PRRO

The officers may check:

whether the RRO/PRRO is registered;
whether all sales go through it;
whether a fiscal receipt is issued;
whether the receipt contains the mandatory details;
whether goods are programmed correctly;
whether the product name matches the actual sale;
whether the customs (UKT ZED) code is shown for excise goods;
whether excise stamp details are shown;
whether transactions go through the proper business entity;
whether cash on hand matches the RRO data.

On 1 August 2025 the transitional period of reduced fines ended, and failure to use an RRO/PRRO or to issue a proper receipt now attracts financial penalties in full (Article 17 of Law No. 265/95-VR):

100% of the value of goods, works or services sold in breach — for the first violation;
150% of the value — for each subsequent violation.

Each individual sale without a proper receipt may be treated as a separate violation.

Cash transactions

The following may be checked:

recording of cash receipts;
whether actual cash matches the accounting records;
cash documents;
the procedure for depositing and withdrawing cash;
service cash-in and cash-out operations;
documentation of returns;
compliance with internal cash discipline.

Inventory

The officers may analyse:

the origin of goods;
primary purchase documents;
delivery notes;
supplier documents;
inventory accounting;
whether actual stock matches the records;
which business entity the goods belong to.

A particular risk arises where several FOPs or legal entities operate in one set of premises, but goods, staff, cash registers and documents are not actually separated. See our article on business splitting through sole proprietors.

Licences and excise goods

The following are checked:

a valid licence;
whether the licence covers the particular point of sale;
compliance with the rules for selling alcohol, tobacco, e-cigarette liquids and fuel;
product marking;
accounting for and origin of goods;
correctness of fiscal receipts;
compliance with minimum retail prices, where they apply.

Staff

During an on-site inspection the officers may establish:

who actually works at the facility;
on what basis each person works;
whether an employment contract has been concluded;
whether a hiring order has been issued;
whether the STS has been notified;
whether working time is recorded;
whether the actual work matches the documents;
whether employment has been replaced by a contract with a FOP or a civil-law contract;
whether wages are recorded and paid.

Formal registration of an employee does not always eliminate the risk. If the documents do not reflect the actual working arrangements, this may also become the subject of the inspection.

Can the inspectors carry out a stocktake?

The tax authorities are entitled to require a stocktake (inventory count) of:

fixed assets;
inventory;
cash;
certain other assets.

It is important to distinguish between:

the tax authority’s right to require a stocktake;
the stocktake actually being carried out by the business;
the inspectors’ participation in supervising and recording the results.

If such a request is received, you should:

obtain it in writing;
check its connection with the subject of the inspection;
issue an internal order;
appoint a stocktake committee;
properly draw up the inventory lists and results;
record any comments and discrepancies.

Do not carry out a stocktake chaotically on the basis of an oral request alone.

Which documents must be provided

The officers are entitled to receive copies of documents relating to the subject of the inspection.

This is an important limitation.

If the inspection concerns the RRO and cash transactions of a particular shop, a request for all the documents of the group of companies, contracts with all customers, or information about another facility may go beyond the subject of the inspection.

We recommend:

receiving document requests in writing;
checking that they match the subject and period of the inspection;
handing over copies with a list;
keeping a copy of the list;
recording the date and time of handover;
not handing over extra documents “just in case”;
marking documents that contain confidential information or trade secrets.

Original primary, accounting and other documents may not be seized by the tax officers, except in cases provided for by criminal procedure law (paragraph 85.5 of the Tax Code). The Tax Code allows them to obtain duly certified copies of documents relating to the subject of the inspection.

What not to do during an inspection

1. Give oral explanations off the cuff

If an employee does not know the exact answer, it is better to say that the documents or explanations will be provided by an authorised person.

Guesses, inaccurate explanations and attempts to “quickly explain everything” may be recorded in the inspection materials.

2. Hand over documents without a list

Later it may be hard to prove:

what exactly was provided;
when it was provided;
in what form;
whether the STS took those documents into account.

3. Sign documents without reading them

Read carefully:

the assignment;
reports;
lists;
requests;
explanations;
stocktake results;
the inspection report.

If a document contains inaccuracies, note them in writing before signing.

4. Alter or create documents after the inspection has begun

Do not:

register an employee retroactively;
alter cash documents;
create primary documents for goods with a false date;
correct electronic data;
delete records.

Such actions can make the situation much worse.

5. Refuse admission automatically

Refusing admission is not a universal defence. If a court finds the order lawful, the business may face an administrative arrest of property and other adverse consequences.

How long an on-site inspection may last

Under paragraph 82.3 of the Tax Code, an on-site inspection may not last longer than 10 days.

It may be extended by no more than 5 days if one of the following grounds exists:

an application by the business itself, if it needs time to submit documents;
shift work or cumulative working-time accounting at the business or its facility.

An extension must be formalised by a decision of the head of the tax authority, their deputy or an authorised person.

How the results are recorded

If violations are found, a report (akt) is drawn up.

If no violations are found, a certificate (dovidka) is drawn up.

Under paragraph 86.1 of the Tax Code, the report or certificate following an on-site inspection:

is drawn up in two copies;
is signed by the inspectors;
is signed by the person who carried out the sales transactions, the taxpayer or their representative;
is registered no later than the next business day after the inspection ends.

The inspection report itself is not yet a decision to impose a fine.

On the basis of the report and the review of the inspection materials, the tax authority may issue a tax assessment notice (podatkove povidomlennia-rishennia).

Should you sign the inspection report?

Refusing to sign the report does not cancel it or stop a decision from being made.

If the taxpayer disagrees with the findings, it is better to:

read the report carefully;
note the inaccuracies;
write when signing: “We disagree with the findings of the report. Objections and additional documents will be submitted within the statutory time limit”;
obtain your copy;
prepare reasoned objections.

Signing the report does not mean automatic agreement with all its findings.

How to file objections to the report

Objections and additional documents may be filed with the tax authority that carried out the inspection.

The deadline is 10 business days from the day following receipt of the report or certificate (paragraph 86.7 of the Tax Code).

Objections should include:

a description of the facts;
breaches of the procedure for ordering or conducting the inspection;
inspectors going beyond the subject of the inspection;
an explanation of each violation found;
references to primary documents;
evidence of proper use of RRO/PRRO;
employment documents;
documents for the goods;
licences;
video recordings;
employees’ explanations;
other materials rebutting the STS findings.

Objections should contain not just general disagreement, but a specific legal and documentary rebuttal of each finding.

The tax authority reviews the objections within seven business days and sends a reply to the taxpayer.

How to challenge a fine

If a tax assessment notice is issued following the inspection, the taxpayer may challenge it:

administratively;
in court.

A complaint to the higher-level tax authority is filed within 10 business days following receipt of the tax assessment notice or other STS decision (Article 56 of the Tax Code).

The complaint should be accompanied by:

a copy of the decision being challenged;
the inspection report;
the objections;
primary documents;
evidence of procedural breaches;
legal reasoning;
other materials supporting the business’s position.

The time limits for going to court depend on whether the taxpayer used the administrative appeal procedure. So once a tax assessment notice is received, do not delay contacting a lawyer.

Step-by-step plan during a tax visit

Stay calm and do not create physical obstacles.
Immediately notify the director, owner, accountant and lawyer.
Check every inspector’s ID card.
Obtain a copy of the order and check the assignment.
Check the entity’s name, address, ground, subject, dates and the list of inspectors.
Record the time of arrival, the handover of documents and all actions of the inspectors.
Appoint one responsible person to communicate.
Do not give hasty oral explanations.
Hand over only documents related to the subject of the inspection, on written request and with a list.
Do not hand over original documents without lawful grounds.
Record procedural breaches and your own comments in writing.
As soon as you receive the report, start preparing objections.

How to prepare the business in advance

The best defence is to prepare for an STS visit before it happens.

We recommend regularly checking:

registration and settings of RRO/PRRO;
correctness of fiscal receipts;
product names and codes;
that all payment methods go through the register;
cash discipline;
actual cash balances;
inventory accounting;
primary documents for goods;
licences and permits;
documents for excise goods;
notifications in Form No. 20-OPP (taxable objects);
the registration of each employee;
notifications of hiring;
timesheets;
contracts with FOPs and civil-law contracts;
documents relating to several entities operating in one set of premises.

Staff also need separate training.

A cashier, sales assistant or administrator should know:

whom to call;
which documents to check;
who is authorised to speak to the inspectors;
what must not be given orally;
how documents are handed over;
how to record the inspectors’ actions.

Typical mistakes

Businesses most often make the following mistakes:

they believe an inspection is impossible without the director;
they do not obtain a copy of the order;
they do not check the facility address;
they admit persons not named in the assignment;
they allow all employees to talk to the inspectors;
they hand over documents without a list;
they provide information unrelated to the subject of the inspection;
they automatically refuse to sign the report;
they miss the deadline for objections;
they wait for the tax assessment notice instead of building a legal position immediately after the inspection.

Conclusion

An on-site tax inspection can indeed begin without warning.

But this does not mean the officers may conduct it without a lawful ground, a properly issued order, an assignment and official ID cards.

The main task of a business in the first minutes of an inspection is to:

check the inspectors’ authority;
record all documents and actions;
prevent chaotic explanations;
keep the inspection within its limits;
hand over documents only with a list;
involve a tax lawyer in good time.

Refusing admission without sufficient legal grounds may create additional risks, including an administrative arrest of property. At the same time, unconditional admission without checking documents and without legal support can also seriously weaken the company’s position.

Legal framework

Tax Code of Ukraine No. 2755-VI — subpara. 20.1.10 of para. 20.1 of Art. 20 (test purchase), subpara. 75.1.3 of para. 75.1 of Art. 75 (definition of an on-site inspection), Art. 56 (appeals), Art. 80 (procedure and grounds for on-site inspections), Art. 81 (admission to inspections), para. 82.3 of Art. 82 (duration), para. 85.5 of Art. 85 (ban on seizing originals), Art. 86 (recording results and objections), Art. 94 (administrative arrest of property)
Law of Ukraine No. 265/95-VR “On the Use of Cash Registers in Trade, Catering and Services” — Art. 3 (obligations of businesses), Art. 17 (financial penalties)
Labour Code of Ukraine — Art. 24 (employment contract and notification of the STS), Art. 265 (liability for unregistered workers)

ARGUS Consulting group carries out preliminary tax audits, prepares staff for visits by the authorities, supports clients during on-site inspections, prepares objections to inspection reports and challenges tax assessment notices administratively and in court — see tax dispute support and legal support for business.

Legal framework as of 02.10.2026.

This article is for information only and is not individual legal advice. Legislation changes — contact us for a decision on your specific situation.