On September 9, 2025, the Cabinet of Ministers of Ukraine, as the initiating body, registered Bill No. 14023-1 with the Verkhovna Rada of Ukraine “Draft Law on Amendments to the Law of Ukraine ‘On Accounting and Financial Reporting in Ukraine.’”

According to the explanatory note accompanying the bill, its purpose is to reduce the administrative burden on businesses by simplifying business documentation, specifically by allowing primary documents confirming the provision of services paid for by non-cash means to include information regarding the position, last name, and signature of only one person—the service provider.

The bill proposes to stipulate that a primary document confirming the provision of a service and paid for by non-cash means shall be recognized as valid provided it contains the mandatory details specified by law, and may not contain the signature or details of the service customer’s representative.

Simply put, if a service is paid for by non-cash means (bank transfer), then the certificate of work performed or services rendered, drawn up and signed only by the service provider, will be considered a valid primary document.

Key conditions for applying this rule:

1. This applies only to services. For the supply of goods, where there is a physical transfer of tangible assets, a signature from both parties remains mandatory.
2. Payment must be made by non-cash means. Cash payments are not covered by this rule.
3. The certificate must still contain all other required details: the document’s title, date of preparation, company name, description and scope of the transaction, unit of measurement, etc.

The current version of Article 9 of the Law of Ukraine “On Accounting and Financial Reporting in Ukraine” requires that the source document contain, among other things, “the positions and last names of the persons responsible for carrying out the business transaction and ensuring its proper documentation” and their “personal signature or other information that allows for the identification of the person who participated in the business transaction.”

At the same time, in practice, business entities often encounter difficulties in documenting business transactions involving the provision of services, particularly regarding the signing of primary documents by both parties and their proper storage.

Since the fact of proper fulfillment of an obligation must be confirmed by primary documents that meet the requirements of the Regulation on the Documentation of Accounting Records, approved by Order of the Ministry of Finance of Ukraine No. 88 dated May 24, 1995, and Article 9 of the Law of Ukraine “On Accounting and Financial Reporting,” the absence on a primary document of one of the signatures, information regarding the position, and/or the last name of the person responsible for carrying out the business transaction on behalf of the customer limits the recognition of such a document as a valid primary document used for accounting and tax purposes. 

Currently, administrative courts are literally inundated with cases in which the subject of dispute is the appeal of tax authority decisions to assess additional tax liabilities and penalties due to the failure to confirm the authenticity of business transactions, including due to the absence of mandatory details in the source documents.
Tax authorities interpret the law unambiguously: a certificate of work performed or services rendered must bear the signatures of both parties—the contractor and the client. If the customer’s signature is missing, the document is defective, and therefore, the transaction did not take place.

Thus, the proposed changes will establish, at the legislative level, the possibility for service providers to use unilaterally signed source documents to formalize service transactions, unless otherwise specified in the contract terms.

Overall, for service providers, the changes proposed in the bill are a huge relief, as they will no longer have to wait several months for signed certificates from clients. Once payment is received, the transaction is closed in the accounting records, with the service provider retaining its own copy of the document. The risk of claims from the tax authorities due to the formal absence of a signature and/or the name of the person responsible for the business transaction on the client’s side will also be reduced.

At the same time, despite the simplification proposed in the bill, the contract with the client will still play a key role. Therefore, to avoid any future disputes, it is recommended to include a clause in the contract that: specifies a clear procedure and deadlines for the parties to exchange and sign certificates of completed work or services rendered; specify the deadline for the client to send the contractor a written, reasoned refusal to sign the certificate, and clearly define the conditions under which the services will be considered accepted by the client in full and of proper quality; and a certificate of work performed or services rendered signed unilaterally by the contractor shall be considered a valid primary document confirming the provision of services.

Such a clause will hold the client accountable and serve as additional protection for the contractor in the event of potential disputes. There is also an important nuance for customers: in essence, the very fact of non-cash payment by the customer will be equated to their agreement that the service was provided properly. This makes sense, since no one would pay for something they did not receive or with which they disagree; therefore, to protect your rights and interests, you must carefully verify—before making payment—whether the service was actually provided in the scope and quality agreed upon in the contract. 

If you, as the customer, have any complaints—do not remain silent or make the payment; instead, immediately send your written comments to the service provider, because once payment is made, it will be much more difficult to prove your case.

Overall, the proposed changes represent a logical step toward supporting business. They not only reduce the administrative burden and bureaucracy but also adapt Ukrainian legislation to modern digital realities, bringing us closer to international practices.

Of course, this does not eliminate the need to conduct business in good faith and to pay close attention to the terms of contracts. On the contrary, the importance of a well-drafted contract is only increasing. But most importantly, this initiative removes an archaic barrier that has created unnecessary problems for honest entrepreneurs for years.

Author: Attorney Tetyana Borisova. Barristers