Launch of e-Excise System in Ukraine Threatened by Technical Problems
The e-Excise system, set to commence in Ukraine on November 1, 2026, faces significant challenges as it remains unprepared for full-scale functional testing just six months before its launch.
As of November 1, 2026, Ukraine is scheduled to implement the e-Excise system, designed to streamline the accounting and control of excise goods. However, despite the impending launch date, the system has yet to transition into a stabilization phase and is not ready for comprehensive functional testing. This situation raises concerns among market participants, who are already noting numerous issues that could hinder the successful implementation of the system.
Currently, ongoing adjustments to the e-Excise system complicate businesses' preparations for its rollout. The European Business Association reports that participants from the tobacco and alcohol markets, as well as retail, have expressed worries regarding the system's current state.
According to data from the State Tax Service, only 0.5% of the retail segment is registered within the system, despite testing having commenced three months ago. This indicates that businesses are struggling to adapt to the new conditions, which could lead to significant financial losses.
Businesses are warning that any malfunctions or system shutdowns post-launch could result in daily losses to the state budget of approximately 500 million UAH. These estimates were shared by member companies of the European Business Association during an expert discussion held on April 1. Market participants emphasized that several critical technical and regulatory issues remain unresolved, casting doubt on the system's readiness for launch within the designated timeframe.
Among the primary technical problems highlighted by businesses, several key points stand out. Firstly, the promised documentation fixation was not completed by January 1. Although the documentation was supposed to be finalized, businesses continue to receive new releases and changes, which hampers stable integration and systematic testing.
Secondly, certain elements of the system's basic functionality are missing. For instance, incomplete integration of the Unified Register of Storage Locations means that not all storage sites are represented in the system, and some records lack structured addresses. This complicates the creation of economic operators' objects, which are essential for forming electronic excise documents (EEDs), effectively blocking the testing of key functionalities such as product movement and EED exchange.
Moreover, the offline application is critically unprepared. The law allows for operations for up to 72 hours in the event of a system failure, yet the technical documentation for the offline solution was only provided at the end of February and is not complete. Mobile versions are still not ready for use, and installation is currently impossible.
Market participants also pointed out legislative risks. During the development and testing of the system, inconsistencies were identified that require legislative amendments. The relevant draft law has yet to be submitted, creating an additional risk: even after technical integration is completed, some processes will need to be reviewed or reworked following the adoption of changes.
Participants in the market stressed that for the successful launch of the e-Excise system on November 1, it must be completed, stable, and fully tested, with the legislative framework thoroughly regulated. The business community urges for swift action to ensure both the system and the regulatory aspects are in proper order, allowing for a timely launch without risks to the state and the market.
Specifically, the business community insists on the following steps: finalizing the system's functionality and ensuring the possibility of comprehensive functional testing across the entire supply chain. Representatives from business associations such as Ukrtyun, the American Chamber of Commerce, the Union of Ukrainian Entrepreneurs, the Ukrainian Food Retail Alliance, and Ukrhorilka, as well as experts from the Ministry of Finance, the State Tax Service, the State Customs Service, and the Poligrafkombinat Ukraine, participated in discussions on the challenges of using e-Excise.
It is worth noting that on December 26, 2025, the Cabinet of Ministers adopted a resolution postponing the electronic system for the circulation of alcoholic beverages, tobacco products, and electronic cigarettes (e-Excise). The situation regarding the preparation for the system's launch remains under close scrutiny by the business community and government agencies.