The document management revolution that has been discussed for years is finally becoming a reality. Draft Law No. 14023 (status: “prepared for signing”) allows businesses to отказаться from bilateral service acceptance acts. However, “simply stopping the signing of acts” is a direct path to fines and lost court cases.

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When is an act no longer required?

Under the new version of the law, you may omit the service acceptance act only if both of the following conditions are met:

Contractual clause: Your written agreement explicitly states that the confirmation of services rendered is an invoice, and that it has the status of a primary accounting document.

Fact of payment (or absence of objections): Payment of the invoice by the client automatically confirms that the services have been fully rendered and accepted.

Attention! For works that result in a tangible outcome (construction, repairs, manufacturing), we still strongly recommend keeping acceptance acts. Invoices work best for services: rent, marketing, IT support, consulting, and legal services.

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What must an invoice contain to become a “legally valid primary document”?

A simple piece of paper labeled “Invoice” will not replace an act. To comply with the Law “On Accounting and Financial Reporting,” an invoice must include the following mandatory details:

Document title: “Invoice” or “Invoice-Act.”

Date of issue: This date will be considered the date of the business transaction.

Company name: Full legal name of the supplier issuing the document.

Description and scope of the transaction: Instead of vague wording like “services under the agreement,” specify clearly: “Tax consulting services for February 2026.”

Unit of measurement: Number of hours, months, or simply “1 service.”

Amount and currency: The exact amount payable, including VAT (if applicable).

Signature of the service provider: Position and signature of the person responsible for the transaction.

Important: The customer’s signature becomes optional if your contract allows for unilateral document issuance.

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“Golden Rules” for Your Contracts (Checklist)

To ensure the tax authorities do not disallow your expenses, include the following clauses in your contracts:

Invoice status:

“The Parties agree that the primary document confirming the provision of services shall be an invoice issued unilaterally by the Service Provider.”

Acceptance mechanism:

“Payment of the invoice by the Customer constitutes unconditional confirmation of acceptance of the services in full and without reservations.”

Time limit for claims:

“The Customer may submit claims regarding service quality within 3 business days from receipt of the invoice. If no objections are received, the services shall be deemed accepted.”

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Where Do the Risks Remain?

For VAT payers: A tax invoice is still registered based on the “first event” rule. If the first event is the issuance of the invoice (and not payment), you must ensure that the invoice date is properly recorded in your document management system.

Foreign trade contracts: Currency control by banks is becoming more flexible, but for international audits it is advisable to clearly reference the contract number and date in the invoice.

Substance of services: Remember, an invoice is only a form. If you paid UAH 1 million for “marketing research” but have no actual report, the tax authorities may still deem the transaction fictitious.

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Conclusion

Switching to invoices means enormous savings in time and paper. It is a step toward modern digital business. However, this step must be accompanied by a thorough review of your contracts.

Tip from Honcharuk & Partners: Do not replace acts with invoices overnight. Run a pilot project with a few loyal counterparties and update your contracts in line with the new version of the Accounting Law.