With no establishment and no Ukrainian VAT registration, the ERPN and SAF-T do not reach you – imports are documented on the buyer's side. Revisit if you set up locally or start selling digital services into Ukraine (a declaration-based regime, without ERPN duties per the sources read).

Ukraine's VAT registration for non-resident digital-service providers runs on simplified declarations without ERPN tax-invoice registration, per the sources read. A local establishment or full VAT registration is a different position – ERPN duties attach there, and SAF-T follows the taxpayer categories. Confirm which regime you are in before relying on an exemption.

ERPN registration of VAT tax invoices already applies to you like any VAT payer. The date to plan for is 1 Jan 2027, when SAF-T UA extends to all taxpayers – start mapping your accounting data to the XML structure now, because the two-business-day response window leaves no room to build the file after the request arrives.

Your VAT tax invoices register electronically in the ERPN with qualified signatures – a registration failure blocks your customer's VAT credit. As a large taxpayer (income above UAH 500 million) you have also been in SAF-T UA since 1 Jan 2025: the file is due within two business days of a request, so it has to be generatable on demand, not assembled when asked. SAF-T UA 2.0 is the current structure.