Bill No. 14023 in Ukraine: Acts of Completed Works Become Optional and Invoices Can Confirm Services
Time for Action has analyzed the decision of the Verkhovna Rada regarding Bill No. 14023, which abolishes the mandatory use of acts of completed works. This is not about eliminating primary documents or removing oversight. It is about changing the approach to confirming the provision of services. Formally, this looks like deregulation. In practice, it is an attempt to revise one of the most entrenched elements of post-Soviet document workflow.
From now on, parties to a contract may, by mutual agreement, choose not to prepare an act of completed works and instead confirm the provision of services with an invoice signed by the contractor. Such an invoice is recognized as a primary document for accounting and tax purposes. The law does not prohibit the use of acts. It simply makes them optional. Businesses gain the right to choose: continue operating under the previous model or move to a more flexible format. The Ministry of Economy emphasizes:
“We are consistently reducing regulatory pressure on business and removing norms that do not create value but consume time and resources. Abolishing the mandatory nature of acts of completed works is about trust in entrepreneurs and about a modern economic model where the state does not impose unnecessary forms but creates conditions for development. Business should work, scale, and export, not spend hours servicing bureaucracy.”
This statement sets the direction of the reform: the state is stepping away from imposing a specific document format where contractual parties are capable of regulating their relations independently. What exactly do the changes introduce?
- acts of completed works are no longer mandatory;
- companies may continue to use acts if they consider it appropriate;
- by agreement between the parties, an invoice may replace the act.
Oversight is not abolished. Primary documentation remains. Accounting rules remain. Tax requirements remain. What changes is the form of confirmation.
The argument about alignment with European practice is also clearly stated. The Deputy Minister for Digital Development noted:
“We are synchronizing Ukrainian rules with international practice. In the EU, the basic document is an invoice, and Ukraine is moving along the same path toward a simple, transparent, and competitive business environment.”
Indeed, in most EU countries, the invoice serves as the primary document confirming the provision of services. A separate acceptance act is used depending on the specifics of the contract, not as a universal requirement.
However, Ukrainian practice developed for decades within a different logic. Mandatory acts of completed works became part of the monthly routine of thousands of companies. They were signed even when their content effectively duplicated the invoice. According to ministry estimates, preparing and signing one act costs a company on average 200–300 UAH. Monthly expenses related to the circulation of such documents can reach approximately 4,000 UAH per company. Nationwide, potential savings may amount to up to 20 billion UAH per year. These figures are based on prior research. A survey of more than 400 executives and financial directors showed that over 70% of entrepreneurs believed that making acts optional would simplify business operations. Sole proprietors signed up to five acts per month, while legal entities signed up to thirty. Accountants spent more than 13% of their working time administering acts. In large companies, up to 15 employees could be involved in the process. These are not only direct costs related to paper or electronic document flow. They include the time of managers, accountants, and legal staff. They involve drafting, coordination, sending, signing, and returning documents. Across thousands of enterprises, administrative burden becomes a systemic loss of resources.
At the same time, the reform does not mean the automatic disappearance of acts. In complex B2B relationships, long-term contracts, or industries with elevated risks, parties may retain acts as an additional mechanism to confirm performance. The law merely removes the obligation. The changes also affect foreign economic activity. Companies working with international partners often had to explain why Ukraine required a separate acceptance act. Now document flow becomes more understandable for foreign counterparties.
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Under martial law conditions, the speed of decision-making and procedural flexibility acquire particular importance. Businesses operate in an environment of instability, and every step that reduces administrative pressure has practical significance. Bill No. 14023 is a step toward deregulation. It does not alter the tax system. It does not transform the economic model. But it adjusts a specific norm that for years was considered non-negotiable.
In essence, the state declares that the format of confirmation will no longer be centrally dictated. Contracting parties themselves determine how to confirm the performance of works or the provision of services. For small and medium-sized enterprises, this means simplification. For large companies, it creates an opportunity to revise internal procedures. For exporters, it reduces barriers in communication with partners. Will this become a revolution in document workflow? Unlikely. But it is a clear signal that the regulator is willing to reconsider norms that create excessive administrative burden. Most importantly, business receives a choice. And choice in economic relations always implies greater flexibility and greater responsibility for one’s own decisions.
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