STS Electronic Cabinet outage of 24-28 October: what to check and when the Tax Code waives penalties

From 00:00 on 24 October to 17:30 on 28 October 2026, the Electronic Cabinet and several other services of Ukraine’s State Tax Service (STS) worked with restrictions. For accountants, that meant five days of reports stuck in transit, missing receipts and VAT invoices that would not register. Here is what to check now and how the Tax Code protects taxpayers from penalties caused by such an outage.

What happened and what the STS acknowledged

On 28 October the STS announced on its website that system set-up was complete and gave the exact period of restrictions: from 00:00 on 24.10 to 17:30 on 28.10.2026. In the same notice the STS stated that paragraph 42¹.10 of the Tax Code applies to this period. It also reminded excise taxpayers of the rules for registering excise invoices (paragraph 231.6).

This matters because the Tax Code links taxpayer protection to the outage being acknowledged by the technical administrator or announced on the official STS website (sub-paragraph 21.1.11 requires the STS to publish the start and end date and time). That announcement now exists.

What the law releases you from

• Administrative and criminal liability. Under paragraph 42¹.10, there are no grounds to hold the taxpayer or its officers liable if a violation was caused solely by the Electronic Cabinet outage.
• Penalties. Sub-paragraph 112.8.7 lists this situation among the circumstances that release a taxpayer from financial liability.
• Late-payment interest. Under sub-paragraph 129.9.5, penalty interest is not charged in this case, and any interest already charged must be cancelled.

The key word in all three rules is “solely”. The release applies where the violation happened because of the outage. A report that would have been late anyway, or a payment that did not depend on the Cabinet, is not covered.

What to check now

• Report receipts. Go through every document sent between 24 and 28 October. Each one should have an acceptance receipt. If there is no receipt or an error came back, resubmit now and keep evidence of the first attempt.
• VAT invoices dated 1-15 October. Under paragraph 201.10 they must be registered by the last day of the month, that is, by 31 October inclusive. That is a Saturday, so do not leave registration to the last day. Check whether invoices sent during the outage are still stuck in the queue.
• Documents awaiting an STS response. Explanations for blocked invoices, applications and requests: check that they arrived and that no deadline is about to expire.
• Payments. Taxes are paid through the bank, so the Cabinet outage alone does not explain a late payment. If you could not obtain payment details or the amount due, document that.

Evidence to keep

The protection works when you can show that the outage itself prevented timely filing. Keep screenshots of errors with date and time, rejection receipts, correspondence with your accounting software provider, and a link to the STS notice of 28 October. If a tax assessment with a penalty or interest for those days arrives later, these materials and sub-paragraphs 112.8.7 and 129.9.5 will be the basis for an objection.

If the tax authority does not acknowledge the error, paragraph 42¹.11 allows the taxpayer to go to court. While the court considers the case, penalties and interest for the consequences of the outage may not be applied.

One more rule for the future: sub-paragraph 17.1.15 allows filing a return on paper during an acknowledged outage if electronic filing is not mandatory for you. For VAT payers and most reports of a limited liability company (TOV) electronic filing is mandatory, so this option does not suit everyone.

Common mistakes after an outage

• Treating a report as filed because the software showed “sent”, although there is no acceptance receipt.
• Leaving invoice registration to the last day of the month while the post-outage queue is still being processed.
• Not keeping evidence and later having nothing to prove that the outage caused the violation.

How we help

We keep the books and file reports for Ukrainian companies under accounting outsourcing, tracking receipts, invoice registration deadlines and STS notices so that outages like this do not turn into penalties. If gaps remain in your books or reporting after the outage, we can help with restoring your accounting records. Get in touch via our contact page.

Prepared by the MK Audit team