Finance & Enterprise Resources 23.07.2026 6 min read

Electronic primary documents: protecting tax credits and expenses

Transitioning to electronic document management requires strict adherence to mandatory fields. Learn how to ensure your digital documents are tax-compliant.

The Law of Ukraine "On Accounting and Financial Reporting in Ukraine" defines a primary document as the fundamental basis for recording business transactions in accounting and tax records. While the transition of Ukrainian businesses to electronic document management (EDM) has significantly accelerated data exchange between counterparties, it has also created a dangerous illusion: that the mere existence of a digital file signed with a Qualified Electronic Signature (QES) automatically makes it legitimate for regulatory authorities.

This is not the case. Tax authorities evaluate electronic documents using the same rigorous criteria as their paper counterparts. Improperly formatted digital primary documents or the absence of mandatory fields pose a direct threat: a company risks losing its right to tax credits and expense recognition, leading to additional tax assessments and penalties.

Legal validity of digital documents: when a document becomes primary

For an electronic document to have legal force and substantiate expenses, it must record the fact of a real business transaction and contain all mandatory fields defined by accounting legislation.

Simply creating a document in an EDM system does not prove that a transaction occurred. If services were not actually provided or goods were not moved, even an electronic act correctly signed by both parties will not protect the company. Tax authorities analyze the actual circumstances: the availability of resources (personnel, transport, warehouses) to perform the operation and the consistency of the document's content with reality.

Mandatory fields: key areas of focus during audits

The absence or incorrect completion of even one mandatory field gives fiscal authorities grounds to reject a document as a primary record. Problems most frequently arise in the following fields:

  • Document title: Must clearly correspond to the nature of the business transaction (e.g., "Act of acceptance and transfer of services rendered").
  • Date of compilation: Must reflect the period in which the transaction actually occurred, not the day the file was uploaded to the system.
  • Content and scope: This is the most vulnerable element. General wording such as "information services" without detailing the work performed is often treated as a high-risk or non-commodity transaction.
  • Positions of individuals: The document must clearly indicate the positions and names of the persons responsible for the transaction and its proper documentation.

Reality of the transaction: why QES without proper description will not protect expenses

Applying a Qualified Electronic Signature (QES) confirms the integrity of the document and identifies the signatory. However, QES does not prove the content of the service itself (e.g., conducting market research or providing IT consulting). If a company cannot provide additional evidence, the existence of an electronic act with a QES alone does not guarantee the preservation of expenses.

To protect expenses for complex or intangible services, an electronic act must contain a detailed description or reference attachments (reports, specifications, calculations) that are an integral part of the document. These attachments must also be properly formatted and signed within the same reporting period.

Typical errors when working with digital primary documents

In practice, companies most often encounter three critical flaws:

  1. Absence of an authorized signatory. The document is signed by an employee who lacks officially delegated authority (via a specific order or power of attorney) to carry out financial and business operations.
  2. Mismatch between the compilation date and the actual transaction date. If services are provided in the current month but the electronic act is created and signed by the counterparty in the next, a period gap occurs, complicating timely expense reporting.
  3. Lack of a clear description of the transaction content. Formal or abbreviated completion of specifications without using standard units of measurement.

How to configure automatic field control in an accounting system

Manually checking every electronic document slows down accounting processes and does not eliminate human error. This problem can be solved by automating control at the corporate system architecture level.

This approach is enabled by an accounting and tax records subsystem built on the UnityBase platform. Thanks to a unified data model, the primary document and the accounting entry exist within the same system. When a responsible manager generates an electronic act, the system automatically pulls the counterparty name, contract, nomenclature, and units of measurement from the procurement or sales subsystem. This eliminates discrepancies between different departments.

Integrated authorization within the platform ensures reliable control over signatories: the system verifies user rights against current personnel orders and powers of attorney. If authority is insufficient, the application of a QES and the transmission of the document to the counterparty are blocked. Thus, the risks of field non-compliance are eliminated before the accounting entries are even formed, and the need for regular reconciliations with separate document management systems disappears.

Checklist for verifying digital primary documents before signing

  • The document title (form) fully corresponds to the economic essence of the transaction.
  • The document compilation date matches the reporting period of the transaction.
  • The names and details of the company and the counterparty are entered without errors.
  • The content and scope of the business transaction are described in detail (avoid general phrases).
  • Units of measurement are correct and correspond to the nature of the services or goods provided.
  • The positions and names of the persons responsible for the transaction are clearly stated.
  • The Qualified Electronic Signature (QES) is applied by a person who has valid authority according to company orders or powers of attorney.

FAQ

Is it mandatory to specify the place of compilation for electronic primary documents?

According to current Accounting Law standards, the place of compilation is no longer on the strict list of mandatory fields. However, to avoid disputes with regulatory authorities regarding transaction identification, it is recommended to specify the city or legal address.

How can the reality of a transaction be proven if the electronic service act lacks a detailed description?

To substantiate expenses for an act with a generalized description, it is necessary to attach detailed reports, calculations, or technical specifications as integral parts. All attachments must also have the appropriate fields and be signed with a QES by authorized persons from both parties.

Which date is considered the creation date if there is a discrepancy in signing dates between counterparties?

A business transaction is recorded in the accounting period in which it actually occurred. The compilation (creation) date specified in the document fields must coincide with this period, even if the counterparty applied their QES at a later time.

Data sources

Tags: UnityBaseelectronic document managementautomation
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