Business discusses the implementation of e-Excise

12/ 06/ 2025

On 10 June, an expert discussion titled “Implementation of e-Excise: Discussing Challenges and Solutions” took place regarding the introduction of the electronic excise system in Ukraine. The event was organised by the European Business Association with the participation of business representatives, expert organisations, and government authorities. Participants shared the results of a three-month trial of the “e-Excise” system in the tobacco and alcohol industries as well as in retail, and discussed the necessary steps for a balanced and effective transition to the new system. During the discussion, the business community reiterated its support for the implementation of e-Excise. However, it stressed that the system is not yet ready for full-scale testing, and companies will have extremely limited time to prepare for its rollout. The law on electronic traceability came into force back in July 2023. While working on the law, an agreement was reached that businesses would have time to test the system from 1 March 2025 to prepare for its full launch on 1 January 2026. However, by 1 March only certain elements of the system were ready for testing. The developers of e-Excise presented a plan that envisages gradual testing of individual modules, with final development and error corrections to be completed by November 2025. Anton Yelisieiev. Pernod Ricard Ukraine. This does not meet the state’s commitment to ensure full testing of the system from 1 March 2025. He emphasised that businesses need the opportunity to properly test the new system – otherwise, there will be serious risks to company operations. Nataliia Fesiun, representing Ukrtyutyun, noted that since 1 March, the software has not been undergoing testing but is still in active development. Full testing is scheduled no earlier than November 2025 – just two months before the systems complete launch. For such a complex state-run system as e-Excise, this timeframe is critically insufficient. Moreover, not only state services but all market participants – from manufacturers to retailers – must be technically prepared. It must be understood that any system failure from 2026 onwards will result in budgetary losses. Given that the tobacco industry is one of the key contributors to the state budget, with expected revenues of around UAH 140 billion, such risks must be avoided. Iryna Demtsiura, representing the American Chamber of Commerce in Ukraine, also highlighted the systems insufficient technical readiness, the incomplete regulatory framework, and the absence of proper testing opportunities for new features. According to estimates, in the event of system disruptions after launch, a single day of downtime could lead to UAH 400 million in budgetary losses. Myroslav Laba from the Union of Ukrainian Entrepreneurs proposed establishing a contingency plan in case of unforeseen technical failures of the system that would prevent businesses from fully operating with the e-Excise system. Without this safeguard, significant losses may occur not only for businesses but also for the state budget. Ruslan Dubas from Auchan Ukraine noted that the retail market supports the implementation of a traceability system, as it will help combat the illegal market. However, he emphasised the need to initiate dialogue with the developers and amend the law to extend the current testing timelines. Market participants underscored that all legal producers support the introduction of the system. However, for effective implementation, the testing period must be extended and formally established in appropriate legislation, which should be initiated and passed by October this year. The suggested delay period proposed by the business community is 12 months. In response to business comments, the Ministry of Digital Transformation has proposed a phased launch of the e-Excise system: starting from January 1, 2026 — in a simplified format, without the track & trace component and with the parallel use of paper stamps, and transitioning to the full operation of the system from July 1, 2026. The State Tax Service reported that the necessary work within its area of responsibility will be completed by October 2025. Svitlana Mykhailovska. Deputy Director, European Business Association. Business supports digitalisation, and it is in the interest of compliant companies for this system to become operational. However, both businesses and state authorities need sufficient time to prepare for its launch – including the opportunity to test the full system, not just individual modules, across all market participants. Yaroslav Zhelezniak, Deputy Chair of the Verkhovna Rada Committee on Finance, Tax and Customs Policy, expressed readiness to initiate the necessary legislative changes to ensure that businesses are given legally mandated time for practical testing. Business associations will prepare and submit proposals for parliamentary consideration to resolve the situation and count on the Government’s support. The EBA is sincerely grateful to company and government representatives who participated in the discussion. Special thanks to the market participants – associations and experts – ACC, Ukrtyutyun, UFRA, Ukrvodka, SUP, and NORT.

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On 10 June, an expert discussion titled “Implementation of e-Excise: Discussing Challenges and Solutions” took place regarding the introduction of the electronic excise system in Ukraine. The event was organised by the European Business Association with the participation of business representatives, expert organisations, and government authorities. Participants shared the results of a three-month trial of the “e-Excise” system in the tobacco and alcohol industries as well as in retail, and discussed the necessary steps for a balanced and effective transition to the new system.

During the discussion, the business community reiterated its support for the implementation of e-Excise. However, it stressed that the system is not yet ready for full-scale testing, and companies will have extremely limited time to prepare for its rollout.

The law on electronic traceability came into force back in July 2023. While working on the law, an agreement was reached that businesses would have time to test the system from 1 March 2025 to prepare for its full launch on 1 January 2026.

However, by 1 March only certain elements of the system were ready for testing. The developers of e-Excise presented a plan that envisages gradual testing of individual modules, with final development and error corrections to be completed by November 2025.

Anton Yelisieiev Pernod Ricard Ukraine

This does not meet the state’s commitment to ensure full testing of the system from 1 March 2025.

He emphasised that businesses need the opportunity to properly test the new system – otherwise, there will be serious risks to company operations.

Nataliia Fesiun, representing Ukrtyutyun, noted that since 1 March, the software has not been undergoing testing but is still in active development. Full testing is scheduled no earlier than November 2025 – just two months before the system’s complete launch. For such a complex state-run system as e-Excise, this timeframe is critically insufficient. Moreover, not only state services but all market participants – from manufacturers to retailers – must be technically prepared. It must be understood that any system failure from 2026 onwards will result in budgetary losses. Given that the tobacco industry is one of the key contributors to the state budget, with expected revenues of around UAH 140 billion, such risks must be avoided.

Iryna Demtsiura, representing the American Chamber of Commerce in Ukraine, also highlighted the system’s insufficient technical readiness, the incomplete regulatory framework, and the absence of proper testing opportunities for new features. According to estimates, in the event of system disruptions after launch, a single day of downtime could lead to UAH 400 million in budgetary losses.

Myroslav Laba from the Union of Ukrainian Entrepreneurs proposed establishing a contingency plan in case of unforeseen technical failures of the system that would prevent businesses from fully operating with the e-Excise system. Without this safeguard, significant losses may occur not only for businesses but also for the state budget.

Ruslan Dubas from Auchan Ukraine noted that the retail market supports the implementation of a traceability system, as it will help combat the illegal market. However, he emphasised the need to initiate dialogue with the developers and amend the law to extend the current testing timelines.

Market participants underscored that all legal producers support the introduction of the system. However, for effective implementation, the testing period must be extended and formally established in appropriate legislation, which should be initiated and passed by October this year. The suggested delay period proposed by the business community is 12 months.

In response to business comments, the Ministry of Digital Transformation has proposed a phased launch of the e-Excise system: starting from January 1, 2026 — in a simplified format, without the track & trace component and with the parallel use of paper stamps, and transitioning to the full operation of the system from July 1, 2026. The State Tax Service reported that the necessary work within its area of responsibility will be completed by October 2025.

Svitlana Mykhailovska Deputy Director, European Business Association

Business supports digitalisation, and it is in the interest of compliant companies for this system to become operational.

However, both businesses and state authorities need sufficient time to prepare for its launch – including the opportunity to test the full system, not just individual modules, across all market participants.

Yaroslav Zhelezniak, Deputy Chair of the Verkhovna Rada Committee on Finance, Tax and Customs Policy, expressed readiness to initiate the necessary legislative changes to ensure that businesses are given legally mandated time for practical testing. Business associations will prepare and submit proposals for parliamentary consideration to resolve the situation and count on the Government’s support.

The EBA is sincerely grateful to company and government representatives who participated in the discussion. Special thanks to the market participants – associations and experts – ACC, Ukrtyutyun, UFRA, Ukrvodka, SUP, and NORT.