Who a Ukrainian group 3 FOP can work with, prohibited activities, foreign trade, taxes, RRO, reporting, income records, payment details, and closure.
A Ukrainian group 3 FOP may work with individuals, Ukrainian FOPs and companies under any tax regime, public-sector customers, and non-residents. The group 2 restriction on service customers does not carry over to group 3. The real risks are usually different: a prohibited activity, a missing KVED in the Single Tax Payers Register, a non-monetary settlement, exceeding the income limit, incorrect RRO treatment, or paying into an outdated account.
This guide is current as of November 5, 2026 and covers a regular Ukrainian group 3 FOP, not an e-resident. Rates, limits, payment accounts, and special wartime rules can change, so every risk below includes a practical check and an official source.
| Pitfall | Possible consequence | What to check |
|---|---|---|
| The KVED is missing from the single-tax register | Exit from the simplified system from the next period | State and Single Tax Payers Register extracts |
| The activity is prohibited | 15% on the relevant income and a mandatory transition | Tax Code paragraph 291.5 and the contract's substance |
| Barter or another non-monetary settlement | 15% on that income and a mandatory transition | A monetary settlement method |
| Payment without a receipt where no exemption applies | Penalties under Law No. 265 | Payment method and what is being sold |
| Outdated payment details | The liability may remain unpaid | The Taxpayer Cabinet and official account details |
For a regular group 3 FOP, the customer's tax status does not create a general restriction. A FOP may sell permitted goods, perform work, or provide services to individuals, other FOPs, companies under either the single-tax or general system, non-profits, public bodies, foreign companies, and foreign individuals. The number of employees is not capped for group 3, although hiring creates separate employer obligations.
This is the key difference from group 2: its rule limiting service customers to the public and other single-tax payers does not apply to group 3. A broad customer base does not remove activity prohibitions, sanctions, currency-control rules, licensing, or the requirement to operate within registered KVEDs.
There is no separate list of customers prohibited specifically for group 3. Paragraph 291.5 stating that non-residents cannot themselves be single-tax payers concerns the taxpayer's status; it does not prohibit a Ukrainian FOP from serving a foreign client. The answer therefore starts with the subject and terms of the transaction, not the customer's tax regime.
Do not enter a transaction if its actual substance is an activity prohibited under the simplified system, if the activity is missing from the registers, or if sanctions or another special law prohibit it. Also review arrangements that resemble employment: calling an agreement 'FOP services' does not remove reclassification risk where the customer controls working hours, location, and the process like an employer.
Group 3 accommodates many services, trade, manufacturing, and hospitality activities, but not every business. Paragraph 291.5 excludes gambling and lotteries, currency exchange, most excise-goods transactions, extraction and sale of most mineral resources, financial intermediation, enterprise management, specified postal and telecommunications services, art and antiques trading, tour-event organisation, audit, and technical testing. Security services were added on January 1, 2026. The Code contains narrow exceptions for certain goods and professions; they should not be extended by analogy.
Renting property also has limits: a single-tax FOP cannot rent out land exceeding 0.2 hectares in total, residential property exceeding 400 square metres, or non-residential property exceeding 900 square metres. Some permitted activities still require a licence, permit, inventory records, or a particular rate.
Check both the KVED in the state register and the activities in the Single Tax Payers Register. An unlisted activity requires a group 3 FOP to leave the simplified system from the next period. One nuance matters: subparagraph 293.4.2 expressly applies the 15% rate for an unlisted activity to groups 1 and 2, so a missing KVED alone should not automatically be described as a 15% trigger for group 3. If the activity is also prohibited, a separate rule does impose 15%.
| Situation | Consequence | Action |
|---|---|---|
| Permitted activity and KVED in both registers | Basic condition met | Check licensing, RRO, and VAT |
| KVED in the state register but not the single-tax register | Simplified status at risk | Add it before operations |
| Activity prohibited by paragraph 291.5 | Group 3 cannot be used | Choose another model before income |
| The rule has an exception | Only its exact wording applies |
A group 3 FOP may work with foreign customers, export permitted goods, work, and services, and receive foreign-currency payments. Before the first transaction, confirm the KVED in both registers, the contract and invoice subject, and the payment route into an account used for business activity.
Foreign-currency income is converted to UAH at the NBU's official rate on the income receipt date. For a credit to the FOP's foreign-currency account, this is the date the funds reach the account. Do not automatically treat a Payoneer, Wise, or similar platform balance as a risk-free Ukrainian business-account credit: the tax authority's position depends on the transfer route and timing. An unusual setup may need an individual ruling, while the bank-statement guide to group 3 FOP income helps classify ordinary payments.
Exports and imports of goods may also be subject to currency supervision, settlement deadlines, and NBU exceptions, which can change during martial law. Single-tax payers must also settle for goods, work, and services only in monetary form; barter creates a tax breach.
Core taxes depend on VAT status: 5% single tax without VAT, or 3% plus separate VAT accounting and payment. A 1% military levy also applies in 2026. SSC is generally at least UAH 1,902.34 per month even with no income; statutory exemptions are covered below.
The 2026 annual income limit is UAH 10,091,049, equal to 1,167 minimum wages set on January 1. A separate guide covers 2026 group 3 FOP taxes, the limit, and reporting, while the military levy guide explains the 1% charge. Employee taxes and contributions are separate from the FOP's own 5% or 3%.
| Payment | Amount | Key point |
|---|---|---|
| Single tax without VAT | 5% of income | Expenses do not reduce the base |
| Single tax with VAT | 3% plus VAT | VAT records and returns apply |
| Military levy | 1% of income | Included in the single-tax return |
| Minimum SSC | UAH 1,902.34 per month | Unless a statutory exemption applies |
| Annual limit | UAH 10,091,049 | For calendar year 2026 |
Group 3 has no ordinary one-month tax holiday. Paragraph 295.5 gives that option only to group 1 and group 2 FOPs without employees. If a group 3 FOP receives no income during a holiday, income-based single tax and military levy are zero, but earlier liabilities, records, returns, and SSC do not disappear.
Martial law also does not give every group 3 FOP a blanket right to stop paying. In 2026, SSC is mandatory for most FOPs. Exceptions include old-age pensioners, people with disabilities, employed FOPs for whom an employer paid at least the minimum contribution, and certain special categories.
A separate relief applies to mobilised or contract service members who registered as FOPs before conscription or the contract: subject to the special rule, they are relieved from single tax and military levy during service, while SSC relief follows Law No. 2464. A person registering only after conscription or signing the contract does not qualify.
A group 3 FOP files the return for quarterly periods within 40 calendar days, using cumulative figures. Single tax and military levy are paid after the return, while SSC has a separate quarterly deadline. Check exact dates in the FOP tax calendar.
If Q1, the half-year, or nine months contains no income and no other reportable items, the tax authority permits the interim return to be omitted. Earlier income still appears cumulatively. Review the annual SSC Appendix 1 obligation separately: omitting an interim nil return does not automatically remove year-end duties.
The old registered income book has been abolished for a non-VAT single-tax FOP, but records remain mandatory. A FOP at 5% keeps monthly free-form income records. A FOP at 3% with VAT uses the standard form under Ministry of Finance Order No. 405. See the guide to keeping income records without the old book.
Group 3 is not exempt from RRO or PRRO merely because turnover is small. For settlement transactions such as cash, card at a POS terminal, or internet acquiring, the general rule requires a fiscal receipt unless a specific exemption applies.
A direct transfer from the buyer's account to the FOP's current account using full IBAN details is not a settlement transaction. Separately, Article 9(14) of Law No. 265 exempts payments specifically for services when made exclusively through remote banking systems and/or money-transfer services. That exception should not be extended automatically to goods.
For cash on delivery, marketplaces, and payment links, identify who receives the money, when settlement occurs, and who must issue the fiscal document.
| Payment method | Baseline rule | Key point |
|---|---|---|
| Cash or card at a POS terminal | RRO/PRRO is generally required | A special exemption may apply |
| Internet acquiring for goods | RRO/PRRO is generally required | The intermediary's role matters |
| Direct IBAN transfer | RRO/PRRO is not required | It must be a genuine bank transfer |
| Service through remote banking | Article 9(14) may apply | The exception is not for goods |
| Cash on delivery or a mixed flow | Analysis is required | Who receives payment and issues the document |
A FOP does not have one universal IBAN. Single tax, military levy, and SSC use separate accounts; details depend on the payment, tax address, and community. The guide to tax payment accounts by community explains why location matters.
Before every payment, open the private Taxpayer Cabinet, choose the budget-settlement view, and verify the specific liability's details. The tax authority's official directory is an alternative. Do not copy an old IBAN: military levy accounts changed on July 1, 2026, and simplified-system FOPs use budget revenue code 11011700.
After payment, confirm that it was credited. The correct amount sent to the wrong account or code may leave the liability unpaid.
For a group 3 FOP, the 15% rate clearly applies to income above the annual limit, income from non-monetary settlements, and income from prohibited activities. These breaches also require a move to the general system from the next period.
A KVED missing from the single-tax register is a separate ground for leaving the simplified system. Do not apply to group 3 the wording in subparagraph 293.4.2 that imposes 15% for an unlisted activity on groups 1 and 2. Late filings, SSC arrears, missing receipts, and wrong-account payments each have their own procedures.
| Breach | Consequence | First action |
|---|---|---|
| Annual limit exceeded | 15% on the excess and exit | Fix the amount, report it, and file the notice |
| Non-monetary settlement | 15% and transition | Stop the method and identify the period |
| Prohibited activity | 15% and loss of eligibility | Stop operations and confirm transition date |
| Unlisted KVED | Exit from the next period | Add it for future work and assess the past |
| Settlement without a receipt | Penalties under Law No. 265 | Identify transactions and fix the process |
| Wrong payment account | Debt may remain | Check the ledger and apply under the procedure |
Closure begins with state registration of termination. The state-register entry does not erase debt or complete reporting. The final reporting period is the period in which the tax authority receives the registrar's notice.
Generally, a single-tax FOP files the final return within 40 calendar days after the quarter of termination, marks it for liquidation, reports single tax and military levy, and includes Appendix 1 when liable for SSC as a FOP. The FOP then settles liabilities, checks integrated ledgers, resolves overpayments or debt, and closes business accounts. Do not continue business in the name of the closed FOP.
A narrow exception exists: the tax authority permits no return after termination when there are no reportable figures, the FOP is exempt from own SSC as an eligible pensioner or person with a disability, and no minimum tax liability must be calculated. Check all three conditions before relying on the exception; zero income alone is not enough.
Records cannot be destroyed immediately. A 2026 tax authority explanation refers to retaining source documents for at least 1,825 days after termination and notes that an audit may follow.
Ask these questions before the first payment. If an answer is unclear, pause and verify the specific transaction.
These answers cover a regular Ukrainian group 3 FOP as of November 5, 2026.
Individuals, FOPs and companies under any tax regime, public and non-profit organisations, and non-residents. Restrictions depend on the activity and transaction terms.
There is no customer list based on tax regime. Transactions prohibited by law or sanctions, prohibited activities, and work outside registered KVEDs are not permitted.
In 2026: 5% without VAT or 3% plus VAT, a 1% military levy, and minimum SSC of UAH 1,902.34 per month unless exempt.
Yes, with matching KVEDs, foreign-trade documents, a proper payment route, UAH records for foreign-currency income, and compliance with restrictions.
The ordinary one-month relief is only for groups 1 and 2 without employees. With no group 3 income, income-based tax and levy are zero, but SSC may remain.
For settlement transactions unless exempt. A direct IBAN transfer needs no RRO; services have an exemption under Article 9(14) of Law No. 265.
The old registered book is not required without VAT, but monthly free-form records remain mandatory. A VAT-registered FOP uses the standard form.
Generally, a final return marked for liquidation, plus Appendix 1 when the FOP is liable for own SSC. An exception requires no reportable figures, an applicable SSC exemption, and no minimum tax liability.
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