Facsimile signatures on primary documents in Ukraine: Ministry of Finance Order No. 514
From 30 October 2026, Ukraine’s accounting Regulation No. 88 no longer contains a rule on facsimile signatures on primary documents. This is not a ban: a facsimile stamp can still be used on acts and delivery notes, but only on the terms of Article 207 of the Civil Code, that is, with the written consent of the parties that includes specimen signatures.
For most companies this means reviewing contracts with counterparties and their own templates of primary documents. Below we explain what exactly Ministry of Finance Order No. 514 changed, who is affected and what to do so that neither the State Tax Service (STS) nor the auditor questions your documents.
What has changed
By Order No. 514 of 2 October 2026, the Ministry of Finance amended the Regulation on Documentary Support of Accounting Records (Regulation No. 88). The order was registered with the Ministry of Justice on 15 October 2026 under No. 1386/46780 and published in the Official Bulletin of Ukraine No. 88 of 30 October 2026. Under clause 3 of the order, it takes effect on the day of official publication, i.e. 30 October 2026. Text of the document: zakon.rada.gov.ua.
There are two changes.
Facsimile signatures. The second paragraph of clause 2.4 of Regulation No. 88, which described the use of a facsimile reproduction of a signature on primary documents, has been deleted. Accountants used to cite this paragraph as a standalone legal basis for facsimile signatures. The accounting regulation no longer provides such a basis, and the only remaining rule is part 3 of Article 207 of the Civil Code: a facsimile is permitted in cases established by law or other acts of civil legislation, or by written consent of the parties containing specimens of the corresponding analogue of a handwritten signature.
In-house templates of primary documents. Clause 2.6 now specifies that when a company develops its own forms of primary documents (because no standard or specialised forms exist), it must take into account the specific documentation rules for certain business transactions set out in Article 9 of the Law of Ukraine on Accounting and Financial Reporting. A practical example: the Law allows an act on services rendered, work performed or lease to be drawn up and signed by the supplier alone, if the written contract provides for this and the other conditions of the Law are met. An in-house act template may expressly provide for such a unilateral procedure.
| Rule in Regulation No. 88 | Before | From 30 October 2026 |
|---|---|---|
| Facsimile on primary documents (clause 2.4) | A separate paragraph described the use of a facsimile on primary documents | Paragraph deleted. The terms of use are governed solely by part 3 of Article 207 of the Civil Code: written consent of the parties with specimen signatures |
| In-house forms of primary documents (clause 2.6) | A company develops its own forms where no standard or specialised ones exist | The same, but taking into account the specific documentation rules for certain transactions under Article 9 of the Accounting Law, including unilateral acts |
Who is affected
- companies where the director does not sign every document by hand and managers put a facsimile stamp on acts, delivery notes, invoices and powers of attorney;
- accounting teams that accept acts with facsimile signatures from suppliers: the risk sits with the buyer, since it is the buyer’s expenses and VAT credit that depend on a proper signature;
- companies with in-house templates of primary documents, including those working under contracts with unilateral acts;
- organisations whose reporting is checked by an auditor or a donor: an act with a questionable signature will not support the transaction during the review.
What to do and by when
The order is already in force and sets no separate transition period, so there is no reason to wait.
- Take stock of the documents you sign with a facsimile: acts, delivery notes, invoices, powers of attorney. List the counterparties you work with this way.
- For each counterparty, check whether there is written consent to facsimile signatures with specimen signatures: in the contract itself or in a separate agreement.
- Where there is no consent, or it lacks specimen signatures, sign a supplementary agreement or switch to a qualified electronic signature (QES).
- Update the document flow policy and the accounting policy order: in-house forms of primary documents, signing procedure, cases of unilateral acts under Article 9 of the Accounting Law.
- Train the managers who issue documents to clients: what may be signed with a facsimile and what only by hand or with a QES.
- For incoming documents, add a check to the accountant’s checklist: if a supplier’s act carries a facsimile, is there written consent with a specimen signature from that supplier.
Common mistakes and risks
- “Facsimile signatures are banned.” No. Only the legal basis has changed: it is now the Civil Code rather than the accounting regulation.
- “Nothing has changed.” Also no. If your facsimile practice rested solely on Regulation No. 88 and there is no consent with specimen signatures, the document is in doubt.
- Consent without specimens. A clause saying “the parties allow facsimile signatures” without specimen signatures does not meet Article 207 of the Civil Code.
- Unilateral act without a contract. An act signed by the supplier alone works only where the written contract expressly provides for it and the other conditions of the Law are met.
The cost of a mistake: the STS may refuse to treat a document without a proper signature as a primary document. Expenses for corporate income tax purposes and the VAT credit are then at risk. In an audit, such an act does not support the business transaction, and the auditor will look for other evidence or qualify the report.
FAQ
Are facsimile signatures on primary documents banned in Ukraine from 2026?
No. Ministry of Finance Order No. 514 only removed the paragraph on facsimile signatures from Regulation No. 88. They may still be used in cases established by law or with the written consent of the parties containing specimen signatures (part 3 of Article 207 of the Civil Code).
Do we need a supplementary agreement with a counterparty to use a facsimile?
If the contract already contains written consent to facsimile signatures and specimen signatures, no supplementary agreement is needed. If that clause or the specimens are missing, sign a supplementary agreement or switch to a QES.
Can an act of work performed be signed by the supplier alone?
Yes. Article 9 of the Accounting Law allows a unilateral act on services, work or lease if the written contract provides for it and the other conditions of the Law are met. The updated clause 2.6 of Regulation No. 88 requires this to be reflected in in-house document templates.
How we help
We keep the books of Ukrainian LLCs and check primary documents before the tax authority sees them: facsimile consents, in-house act templates, the accounting policy. If documents for past periods were signed improperly, we help put them in order. See accounting outsourcing for LLCs, accounting recovery and audit services. Contact us via the contacts page.
Prepared by the MK Audit team