Invoice Instead of a Completion Certificate: How the New Law Simplifies Document Flow, but Does Not Remove Risks for Business

Since April 1, 2026, Ukraine has changed its approach to preparing primary documents for services, works, hiring and lease. Law No. 4791-IX allowed, in certain cases, the use of an invoice or another primary document without the customer’s signature. For business, this looks like a long-awaited simplification less paperwork, fewer delays in month-end closing, fewer situations when accounting departments wait for weeks for one signature to confirm an operation that has already been completed.

But the formula “completion certificates have been canceled” is inaccurate. The issue bilateral completion certificates have not disappeared, but have ceased to be the only possible option for documenting a transaction. The law does not cancel primary documents and does not remove the obligation to confirm business operations. It only allows the parties to agree in advance that confirmation will be a document prepared by the contractor. For entrepreneurs, this is an important change, but it does not work automatically. If a company simply stops signing completion certificates without changing contracts and setting up document flow, it may receive not relief, but tax risks. The new procedure requires proper legal preparation.

Law No. 4791-IX amended Article 9 of the Law of Ukraine “On Accounting and Financial Reporting.” This provision defines what primary documents must look like, on the basis of which operations are reflected in accounting and tax records. Previously, for services, works or lease, the parties usually prepared a bilateral certificate. It contained the signatures of the contractor and the customer and confirmed that the operation had taken place and the result had been accepted.

Now the law allows another option. A primary document may be an invoice or another document signed by the contractor without the customer’s details. This means that the absence of the client’s signature is no longer a violation in itself if the conditions provided by law are met. The first key condition is that the written contract between the parties must directly provide for such a documentation procedure. The contract must state that the primary document is prepared without the details of the customer or tenant. It may provide that confirmation of performance is the contractor’s invoice. It is also advisable to include a rule of tacit acceptance: for example, if the customer has not submitted motivated objections within five working days, the service is considered accepted.

Without such a provision, an invoice without the customer’s signature will not have the necessary legal force under the new procedure. This means that existing contracts must be reviewed. If a company wants to switch to the simplified model, it should sign additional agreements with counterparties or conclude new contracts already containing the relevant provisions. Companies that change nothing in their contracts will effectively remain under the old regime. The second condition is that the primary document must contain the date or period of the operation. This is especially important for monthly services, staged works, subscription-based services, lease or long-term projects. If the document does not show when exactly the service was provided or the work was performed, the business may face problems with correctly reflecting the operation in accounting.

In addition to the date or period, the invoice must also contain other mandatory details of a primary document: the content of the operation, its volume, unit of measurement, and data of the responsible person on the contractor’s side. The law removes the requirement regarding the customer’s details, but does not cancel the general requirements for primary documents. An invoice cannot be an arbitrary payment notice. It must be prepared as a full-fledged accounting document. The third condition is that the operation must be reflected in accounting precisely in the period when it actually took place. A primary document is prepared during the execution of a business operation or immediately after its completion. This is important for tax discipline, especially when it comes to transition periods, advance payments, partial payment or works performed in several stages. The law does not directly require payment to be exclusively non-cash. It also does not make the possibility of applying the simplified procedure dependent on full payment. But payment documents bank statements, payment orders, payment confirmations remain an important part of the evidence base. They should be stored together with the contract, invoice, correspondence and reports. The sectors that may benefit the most from the new procedure are those where monthly signing of completion certificates has long been a technical problem. This concerns IT companies, software developers, marketing agencies, advertising businesses, consulting, legal services, e-commerce and companies that have long been working in an electronic format. For them, the new law may shorten the time spent on document flow and reduce risks related to delays in signatures.

In such businesses, there is often a situation when the service has actually been provided, the client does not object, payment has been made or is expected, but the certificate is stuck because of the customer’s internal bureaucracy. The new procedure allows avoiding this dependence if the parties have properly provided for it in the contract.

At the same time, the simplified procedure does not apply to everyone. A bilateral certificate remains mandatory in cases where special documentation rules apply. These are operations paid for with public funds, contracts for hiring state or municipal property, construction contracts, design and survey works, donation agreements, charitable or humanitarian aid. For these categories of business, the new law does not change the basic rule: a certificate is required.

A separate warning concerns VAT. The new rules on primary documents do not cancel tax invoices. If an operation is subject to VAT, the company must still prepare and register a tax invoice in the Unified Register of Tax Invoices. An invoice without the customer’s signature may confirm a business operation for accounting purposes, but it does not replace special tax documents. The main legal risk of the new procedure is the weaker evidentiary role of a unilateral document compared with a bilateral certificate. A certificate signed by both parties confirms not only the fact of performance, but also the customer’s acceptance of the result. An invoice without the customer’s signature works differently. It may be a full-fledged primary document, but in the event of a dispute, the reality of the operation will have to be proven with a broader set of evidence.

That is why business should not perceive the new law as permission to abandon all documentary support. On the contrary, if a company switches to invoices, it needs to strengthen other evidence: contracts, technical specifications, reports on completed work, correspondence on approval of results, delivery confirmations, payment documents. The absence of the customer’s signature must be compensated by a solid evidence base. The worst scenario is when a company actually stops signing certificates, but does not amend its contracts. In that case, it has neither a bilateral certificate nor a properly prepared invoice under the new rules. For the tax authority, this may become grounds to question expenses and recognize them as not documented. The result may be an increase in taxable profit and additional assessments.

Particular caution is needed with contracts involving advance payments, staged performance or monthly services. The fact of payment itself is not a condition for applying the new procedure, but the date or period of the operation must be determined correctly. If works are performed in parts, it is necessary to clearly understand what volume has been completed, for what period the document has been prepared, and when the operation must be reflected in accounting.

Until official explanations from the State Tax Service or stable court practice appear, in complex cases it is safer to keep more documents, not fewer. For large contracts, long-term relationships with a counterparty or sectors with a higher risk of inspections, a bilateral certificate may remain the more reliable option. The right not to use a certificate does not mean that it should always be abandoned. The practical algorithm for business must be consistent. First, existing contracts should be checked and it should be determined which of them fall under the new rules. Next, it is necessary to decide where it is really worth switching to invoices, and where it is safer to keep certificates. After that, additional agreements should be signed or contract templates updated. They must provide for the procedure for preparing a primary document without the customer’s details, the list of mandatory details, the date or period of the operation, as well as the term for motivated objections.

At the same time, internal document flow should be rebuilt. Accounting, lawyers and managers must equally understand when an invoice can be issued without a certificate, which documents must be stored, who is responsible for sending the invoice, how receipt of the document by the customer is recorded, and what to do if the customer objects to the volume or quality of services.

Law No. 4791-IX is indeed a step toward deregulation. According to estimates by the Ministry of Economy, it may save Ukrainian business up to UAH 20 billion annually by reducing administrative costs. For many companies, this will be real relief after years of formal hunting for signatures. But this relief is neither automatic nor unconditional. It works only where the parties have properly prepared the contract, the invoice contains the necessary details, the operation is reflected in the correct period, and the business has sufficient evidence of its actual performance.

Сertificates have not disappeared, but business has received a choice. This choice can be used for faster and more convenient document flow, but only under the condition of legal accuracy. If the approach is formal, the new law may not reduce risks, but create new ones. If the company properly updates contracts and collects an adequate evidence base, an invoice without the customer’s signature can indeed become a working tool, not a source of problems during an audit.

Tags: accounting, business, completion certificate, document flow, invoice, Law 4791-IX, primary documents, tax risks

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