Have acts of work performed really been canceled?

On February 24, 2026, the Verkhovna Rada of Ukraine adopted Draft Law No. 14023 amending Article 9 of the Law of Ukraine “On Accounting and Financial Reporting in Ukraine” (hereinafter the “Law”), the so-called “cancellation of acts of work performed.”

However, this is not a “cancellation of acts of work performed” nor a revolution in accounting, but rather the cancellation of the mandatory nature of such acts. This is a targeted yet important clarification of the requirements for primary documents in the service sector.

What exactly will change?

Article 9 of the Law was supplemented with a provision stating that the absence of a signature and name from the customer of services (works) or the lessee is not considered a violation of the requirements for primary accounting documents, and such documents can confirm the fact of provided services if three conditions are met simultaneously:

  • the document contains information about the date or period of service provision, execution of works, or lease (the content of the business transaction is defined);
  • the procedure for such documentation is directly stipulated by a written contract;
  • the business transaction is reflected in accounting during the period of its execution.

In other words, the innovations allow not requiring the signature or specific details of the customer in the primary document to confirm the fact of service provision, provided the parties have agreed upon this in the contract in advance.

That is, no one is canceling acts of work performed as such. However, businesses now have a choice to provide a different mechanism for confirming the acceptance of services in the contract, for example, by the contractor providing an invoice to the customer, or through electronic approval without the physical signature of the customer.

Importantly, the innovation does not apply to:

  • transactions paid for at the expense of public funds;
  • lease agreements for state or municipal property;
  • construction contract agreements and design and survey works;
  • agreements on donation, charitable, or humanitarian aid.

In these areas, the documentation requirements remain unchanged: invoice — act of work performed (provided services).

The government explicitly declares that the changes are aimed at bringing Ukrainian rules closer to European practice. In EU countries, the basic document in the service sector is traditionally an invoice, rather than a separate act of acceptance and transfer. Accordingly, the logic of the changes is not to eliminate control, but to simplify the form where it does not affect the substance of the transaction.

If the parties are capable of regulating the procedure for accepting services in the contract and properly reflecting the transaction in accounting, the state should not force them to exchange unnecessary paperwork. At the same time, in areas with heightened public interest, the restrictions logically remain. Ultimately, it all comes down to the quality of the contract and accounting discipline, because a formal act in itself has long since ceased to guarantee the reality of a business transaction.

We await the entry into force of Draft Law No. 14023 from the first day of the month following the month of its publication.

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