Supreme Court’s position: inventory documents must be provided at the beginning of audit

Press service of the State Tax Service of Ukraine, published 04 May 2026 at 13:00 Chapter: News

Business entities are required to provide regulatory authorities with documents confirming accounting and origin of inventories at the beginning of audit. This position was confirmed by the Supreme Court.

Failure to provide such documents will result in fines.

This is about enforcement of provisions of the Law № 265, which obliges business entities to keep records of inventories and sell only those products that are reflected in these records. Business entities must provide supporting documents immediately after the beginning of audit in paper or electronic form.

In its ruling as of 03.03.2026 (case № 140/6980/24), the court emphasized that if previously documents could be submitted during the audit, then after changes in legislation this obligation must be fulfilled at the beginning of audit. This approach has already been outlined in a number of previous court conclusions.

Therefore, according to Article 20 of the Law № 265, for sale of unaccounted products or failure to provide supporting documents after the beginning of audit, a fine in the amount of such products’ cost (but not less than the established minimum) is applied.

Please note that liability may arise both for sale of unaccounted products and separately for failure to provide documents. This applies only to certain categories of individuals-entrepreneurs – single tax payers, namely those who sell technically complex products, medicines or jewelry.

For reference.

Until January 1, 2022, the business entity was required to provide documents confirming accounting and origin of inventories during the audit, and after this date, such obligation must be fulfilled at the beginning of audit.

Conclusions of the Supreme Court are particularly set out in Resolutions as of 11.01.2024 in case № 420/12275/22, as of 27.08.2024 in case № 300/2879/22, as of 30.09.2025 in case № 520/22949/24.

More details are at the link: https://tax.gov.ua/pro-sts-ukraini/struktura/aparat/departament-podatkovogo-auditu/povidomlennya/1006952.html