Unblocking Tax Invoices in Ukraine: What to Do When Registration Is Suspended

Registration of a tax invoice or adjustment calculation in the Unified Register of Tax Invoices may be suspended under the procedure and on the grounds laid down by the Cabinet of Ministers of Ukraine (paragraph 201.16 of the Tax Code of Ukraine). That procedure was approved by Cabinet of Ministers Resolution No. 1165 of 11 December 2019, and decisions to register or refuse registration after a suspension are taken under the Procedure approved by Ministry of Finance Order No. 520 of 12 December 2019. Below, step by step: why registration is suspended, what the receipt states, which documents to file, how long the decision takes and how to challenge a refusal.

Why registration is suspended

Each invoice submitted for registration is first checked against the grounds for unconditional registration – for example, where it reflects only transactions in goods or services whose codes are listed in the taxpayer’s Data Table that has been taken into account, and there is no decision in force that the taxpayer is risky (subitem 4 of item 3 of the Suspension Procedure). If none of these grounds applies, the following are checked:

• the taxpayer – against the taxpayer risk criteria (Annex 1 to the Procedure) and the indicators of a positive tax history (Annex 2); if the taxpayer meets at least one risk criterion, registration is suspended (items 5 and 6);
• the transaction – against the transaction risk criteria (Annex 3); if the transaction meets at least one of them, registration is suspended, unless the taxpayer meets at least one positive tax history indicator (item 7).

What the receipt states

The tax authority automatically sends the taxpayer a receipt confirming the suspension within the operating day (item 10 of the Suspension Procedure). It states (item 11):

• the number and date of the tax invoice (adjustment calculation);
• the taxpayer or transaction risk criterion (or criteria) on which registration was suspended, with the calculated indicator for each criterion;
• an invitation to file explanations and copies of documents under Procedure No. 520.

What happens next depends on the criterion stated: where the suspension relates to the risk of the transaction, the key is explanations and documents for that particular invoice; where it relates to the taxpayer’s risk, removal from the list of risky taxpayers is needed as well (see below).

Which documents to file, and by when

The taxpayer is entitled to file written explanations and copies of documents confirming the information in the invoice (item 4 of Procedure No. 520). The Procedure lists, in particular (item 5):

• contracts, including foreign trade contracts, with their annexes;
• contracts, powers of attorney and acts of the governing body formalising the authority of persons who receive goods on the taxpayer’s behalf;
• primary documents on the supply or purchase, storage and transport, loading and unloading of goods, warehouse documents, inventory records, invoices, acceptance certificates and waybills;
• payment documents and/or bank statements;
• documents confirming product conformity (declarations of conformity, quality passports, certificates) where required by the contract or by law;
• other documents confirming the information in the invoice.

Explanations and documents may be filed within 365 calendar days following the date on which the invoice (adjustment calculation) was drawn up. A single set may be filed for several invoices if they were issued to the same recipient under the same contract or reflect transactions of the same type with the same goods codes (UKT ZED) or service codes (DKPP) (item 6). They are filed electronically (item 7).

How long the decision takes

Explanations and documents are considered by the regional commission. Within 5 working days following the day they are received, it (item 9 of Procedure No. 520):

• decides to register the invoice; or
• sends a notice requesting additional explanations and/or documents; or
• decides to refuse registration if the copies of documents filed were drawn up or executed in breach of the law.

After such a notice, additional explanations and documents may be filed within 5 working days from the day after the notice is received. The commission takes its decision within 5 working days of receiving them; if nothing is filed, it decides to refuse registration within 5 working days after the filing deadline. The grounds for refusal are failure to file, or partial filing of, the additional explanations and documents after a notice, and/or the filing of documents drawn up in breach of the law (item 10). The decision takes effect on the day it is made (item 11).

How to challenge a refusal to register

A refusal can be challenged administratively or in court (item 12 of Procedure No. 520). For an administrative challenge, the Tax Code sets the following rules (paragraph 56.23):

• the complaint is filed electronically with the State Tax Service within 10 working days following the day the decision was made;
• the taxpayer may take part in the hearing in person or through a representative by videoconference;
• the complaint is considered within 10 calendar days, or within 30 calendar days if the taxpayer has asked to take part in the hearing; this period cannot be extended;
• if a reasoned decision on the complaint is not sent within that period, the complaint is deemed fully upheld in the taxpayer’s favour from the following day.

A complaint filed late is not accepted, and a decision that has been challenged in court is not considered under the administrative procedure (items 4 and 8 of the Complaint Procedure approved by the same Resolution No. 1165).

The taxpayer’s Data Table

The Data Table is summary information on the taxpayer’s types of activity (KVED codes) and the codes of goods (UKT ZED) and services (State Classifier) that it supplies, purchases or imports (items 2 and 13 of the Suspension Procedure). It is filed with an explanation describing the activity with reference to the taxpayer’s tax and other reporting (item 14). The regional commission considers the Data Table within five working days and decides whether or not to take it into account; if it does not, it must state the reasons (items 15–17). A decision not to take the Data Table into account can be challenged (item 1 of the Complaint Procedure).

If the company has been classed as risky

Whether a taxpayer meets the risk criteria is decided by the regional commission; the decision is delivered to the taxpayer’s electronic account on the day it is made (item 6 of the Suspension Procedure). On receiving it, the taxpayer may file information and copies of documents showing that it does not meet the risk criteria – contracts, primary and payment documents, bank statements and so on. The commission considers them within seven working days following the date they are received; if no decision is taken within that time, the taxpayer is removed from the list of risky taxpayers. A taxpayer is also removed from the list on the basis of a court decision that has taken legal effect. A decision that the taxpayer meets the risk criteria can be challenged administratively or in court; a complaint is filed within 10 working days following the day of the decision (item 3 of the Complaint Procedure).

Frequently asked questions

How long do I have to file explanations for a suspended invoice?

365 calendar days following the date on which the tax invoice (adjustment calculation) was drawn up (item 6 of the Procedure approved by Ministry of Finance Order No. 520).

Can one set of documents cover several invoices?

Yes, if the invoices were issued to the same recipient under one and the same contract, or reflect transactions of the same type with the same goods codes (UKT ZED) or service codes (DKPP) (item 6 of Procedure No. 520).

What happens if the tax authority does not decide the complaint on time?

If a reasoned decision on the complaint is not sent within 10 calendar days (30 if the taxpayer took part in the hearing), the complaint is deemed fully upheld in the taxpayer’s favour from the day after the period expires (subparagraph 56.23.4 of the Tax Code).

Will a Data Table help with an invoice that is already suspended?

A Data Table that has been taken into account is one of the grounds for unconditional registration: an invoice reflecting only transactions with codes from that table is registered without suspension, provided there is no decision in force that the taxpayer is risky (subitem 4 of item 3 of the Suspension Procedure approved by Resolution No. 1165). This ground is checked when the invoice is submitted for registration; for an invoice already suspended, the route is explanations and copies of documents (item 4 of Procedure No. 520).

This article reflects the position as of October 2026 (Tax Code as amended on 17 September 2026; Resolution No. 1165 as amended on 27 September 2025; Ministry of Finance Order No. 520 as amended on 19 December 2024). Tax legislation changes frequently; take advice before acting on it.

Need help unblocking a tax invoice? A lawyer will analyse the receipt, prepare explanations and documents and, if registration is refused, a complaint or a claim → Unblocking VAT invoices · Tax law