Unblocking Tax Invoices: Procedure, Deadlines, and Required Documents

As of early 2025, the share of blocked tax invoices (TI) decreased from 0.76% to 0.37% of their total number. At the same time, 13–16 thousand enterprises remain in the risk zone, which is still a significant figure for the Ukrainian market.

  • Unblocking a TI is the only way to pass tax control, pay the determined amounts, and continue operating if your invoice has been blocked.

Today, Professional Solutions experts will provide explanations on unblocking TIs, the main reasons for blocking, as well as the algorithms for going through checks and minimizing risks. Use this information to stabilize your company’s operations.

What is a Tax Invoice and Why Does It Get Blocked

In short, it is an official document confirming the supply of goods or services and serving as the basis for forming the buyer’s VAT credit. All TIs are checked automatically through SMKOR (risk criteria monitoring system). If at least one of the criteria is violated, the invoice is blocked. Accordingly, you, as the supplier, must unblock it by submitting proof of the authenticity of the data it contains. Note: blocking may also trigger a tax audit of the company. Therefore, it’s better to be proactive and avoid this mechanism from being launched.

Reasons for Blocking Tax Invoices

There are five categories of factors that may put your TI on the “blacklist”:

Errors in the TI
  • Incorrect UKT ZED or DKPP codes
  • Discrepancies in measurement units between counterparties
  • Technical errors (date, number, nomenclature)
  • Absence of an incoming TI with similar nomenclature

Supply Volume Discrepancies
  • Supply volumes exceed industry averages
  • Mismatch between purchase and sales volumes
  • Inflated prices or high markups without economic justification

VAT Payer Risk
  • The company is listed as risky (per CMU Resolution No. 1165)
  • Low tax burden (<5% of sales volume)
  • No material and technical base or employees
  • Untimely or missing reporting
Risky Transactions
  • Transactions recognized as fictitious or unreal
  • Counterparties have signs of fictitious activity or are risky themselves
  • Change of activity or new counterparties without a cooperation history

Other Factors
  • Tax debt
  • No positive tax history
  • Lack of assets needed for declared operations

There are numerous reasons why a tax invoice may be blocked. So how can it be unblocked? Below, we outline the key steps.

Procedure for Unblocking Tax Invoices

The SMKOR decision appeal algorithm is as follows:

  1. Receipt of Notice #1 After submission of a TI to the Unified Register, if blocked, the taxpayer receives a receipt indicating the reason.
  2. Analysis of ReasonsStudy the specified risk criteria: taxpayer, transaction, nomenclature, volumes, etc.
  3. Preparation of Explanation Draft a written explanation of the business transaction reality, reasons for discrepancies, or technical errors.
  4. Collection of Supporting Documents Attach contracts, invoices, acts, CMR/TTN, certificates, bank statements, warehouse documents, etc.
  5. Submission via Electronic Cabinet Upload explanations and documents in the “Suspension of TI/CR Registration” section. Deadline – up to 365 days from the date of the TI.
  6. Waiting for Tax Committee Decision Within 5 business days, the commission decides whether to unblock or refuse. Result – Notice #2.
  7. Appeal (if necessary) In case of refusal: file a complaint with the tax authority within 10 days or go to court within 3 months.

It may seem straightforward at first glance. In practice, however, you are likely to encounter several challenges, one of which is the need to provide documentary proof of the accuracy of the submitted tax invoice.

Documents for Unblocking Tax Invoices

The primary and essential requirement is to compile and submit information in the form of supporting documents, specifically:

  • Contractual Documents – contracts with counterparties (domestic and foreign), annexes, specifications, powers of attorney
  • Primary Documents – invoices, acts of work performed, delivery notes, acceptance-transfer acts
  • Transport Documents – CMR/TTN, transport vehicle papers, transportation licenses
  • Payment Documents – bank statements, payment orders, cash documents
  • Product Origin Documents – quality certificates, declarations of conformity, customs declarations
  • Production Capacity Documents – equipment passports, lease agreements, photos of production facilities
  • Labor Resources – staffing schedule, employment contracts, qualification certificates
  • VAT Payer Data Table – Form J/F1312302 listing regularly supplied goods/services
  • Explanations to TI – business transaction description, chronology, confirmation of transaction reality
  • Other Documents – licenses, permits, certificates, inventory reports, warehouse/product photos

How should documents be submitted for unblocking tax invoices? They must be filed via the taxpayer’s Electronic Cabinet in PDF format, using the Notification on the submission of explanations and copies of documents (Form J/F1312603). After submission, it is a matter of waiting for the review process.

Deadlines for Unblocking Tax Invoices

What is the deadline for unblocking tax invoices? This is a relevant question, as there is no strictly defined period for the review of your submission. Instead, you should be guided by the following timeframes:

Stage Deadline
Submission of explanations/documents Up to 365 days from the date of TI
Review by the tax commission Up to 5 business days (if no decision – TI is automatically registered)
Administrative appeal Up to 10 calendar days
Court appeal Up to 3 months from receipt of refusal
Stage Deadline Explanation
Filing of explanations and supporting documents Up to 365 days from the date of TI It is essential to meet this deadline; otherwise, the tax invoice will not be subject to review.
Review by the tax commission Within 5 business days from the date of document submission. If no decision is made, the tax invoice is considered registered automatically.
Appeal of the refusal decision Up to 10 calendar days for administrative appeal. A complaint is submitted to the State Tax Service of Ukraine via the Electronic Cabinet.
Judicial appeal Within 3 months from the date the decision is received. You may file a lawsuit if the administrative appeal has not produced a satisfactory result.

Of course, it is worth hoping for a positive decision on the unblocking of tax invoices. However, it is also important to have an action plan in case of refusal. What to do if unblocking is refused If the review result is negative, your next steps will be as follows:

Analysis of Receipt No. 2 Check the reason for refusal: taxpayer risk, nomenclature, volumes, or documents.
Administrative appeal Submit a complaint to the State Tax Service of Ukraine via the Electronic Cabinet (Form J/F1313201) within 10 calendar days.
Preparation of additional documents Add new or updated documents: contracts, acts, waybills (TTN), photos, and the VAT payer data table.
Waiting for the STS decision If the STS refuses again, file a lawsuit within 3 months from the date the decision is received.
Judicial appeal (if necessary) Якщо ДПС знову відмовила – звернутися до суду протягом 3 місяців з дати отримання рішення
Parallel actions Check the taxpayer’s status (whether it is listed as risky).

Of course, this does not guarantee a positive outcome. Therefore, you may need the assistance of Professional Solutions experts — not only to mitigate the consequences of invoice blocking but also to prevent it in the future.

How to reduce the risk of tax invoice blocking

Here are a few basic tips:

Monitor compliance with unconditional registration criteria Check whether the tax invoice qualifies for automatic registration (for example, amount under 50,000 UAH, non-risky counterparty, positive tax history).
Build a positive tax history Ensure timely tax payments, submit reports without violations, and cooperate only with verified counterparties.
Submit the VAT Payer Data Table (Form J/F1312302) Specify the list of goods or services that are supplied on a regular basis, as this significantly reduces the risk of blocking.
Update registration data Promptly update your business activity codes (KVED), address, and types of activities — these factors affect the assessment of risk status.
Ensure a complete set of primary documents Prepare contracts, invoices, acts, waybills (TTN), certificates, bank statements, and photos of the warehouse, equipment, and office.
Monitor the taxpayer’s status Regularly check whether your company has been included in the list of risky taxpayers — if so, submit the necessary documents for exclusion.
Avoid fictitious transactions Do not cooperate with counterparties that show signs of fictitious activity or are classified as risky themselves.
Use the Electronic Cabinet Check messages, receipts, and the status of tax invoices regularly to respond promptly.

And don’t hesitate to contact Professional Solutions. With our help, you will learn how to write an explanation for the tax authorities, get a sample of the required form, and be able to prevent your tax invoices from being blocked.

FAQ

Is automatic unblocking of tax invoices possible?

Yes. If the tax authority has taken into account the VAT Payer Data Table, the invoice may be automatically registered on the 5th business day after being blocked. You will receive a notification confirming the unblocking of the tax invoice.

What happens if the tax invoice is not unblocked?

The buyer will not be able to include the invoice in the tax credit, and there may be fines, audit risks, and potential damage to business reputation.

Can the refusal to unblock a tax invoice be appealed?

Yes. You can file an administrative appeal — a complaint to the State Tax Service within 10 calendar days — or a judicial appeal within 3 months.

What is the deadline for submitting documents to unblock a tax invoice?

Within 365 calendar days from the date the invoice was issued.

How can you find out if the invoice is blocked?

Through the taxpayer’s Electronic Cabinet in the “Suspension of TI/CR Registration” section. You will receive Receipt No. 1 stating the reason for blocking. The same section will later show a notification confirming the invoice has been unblocked.