Unblocking VAT invoices suspended in the register

Suspending registration of a tax invoice blocks the counterparty’s input VAT credit and often puts contractual relationships at risk. How to get it unblocked depends on the reason for the suspension: a risk criterion applied to the transaction, risky-taxpayer status, or a Data Table that has not been taken into account.

When to get in touch

• a receipt suspending registration of a tax invoice or adjustment calculation has been issued
• the company has been placed on the list of risky taxpayers
• the taxpayer’s Data Table has not been taken into account
• the commission has refused to register the invoice

What the lawyer does

• analyses the receipt and identifies the criterion on which registration was suspended
• prepares the explanations and the set of documents for the commission
• prepares and files the taxpayer’s Data Table with a description of the business
• works on removal from the list of risky taxpayers
• challenges the commissions’ decisions through administrative procedure
• prepares the claim, including a separate challenge to risky status

Legal basis

Suspension of the registration of a tax invoice or adjustment calculation in the Unified Register of Tax Invoices is provided for by paragraph 201.16 of the Tax Code of Ukraine; the procedure and the grounds are laid down by the Cabinet of Ministers of Ukraine (the Procedure approved by Resolution No. 1165 of 11 December 2019). Explanations and copies of documents may be filed within 365 calendar days following the date on which the tax invoice (or adjustment calculation) was drawn up (item 6 of the Procedure approved by Ministry of Finance Order No. 520 of 12 December 2019); a complaint against a regional commission’s refusal to register is filed within 10 working days following the day of the decision, under paragraph 56.23 of the Tax Code and the complaint procedure approved by the same Resolution No. 1165; it is considered within 10 calendar days (30 if the taxpayer takes part in the hearing), and if no decision on the complaint is sent within that time, the complaint is deemed upheld.

Tax legislation and case law change frequently, and some provisions apply only for the period of martial law. This page reflects the position as of October 2026.

Frequently asked questions

Will a Data Table unblock an invoice that is already suspended?

No. The Data Table works prospectively: it reduces the risk of future suspensions, while invoices already suspended are unblocked through explanations and documents, or by challenge.

Can risky status itself be challenged?

Yes. On the current practice of the Supreme Court, a decision that a taxpayer meets the risk criteria can be the subject of a court challenge in its own right.

Need legal assistance? Call us or leave a request — a lawyer will contact you and explain what to do in your situation.