Business highlights eExcise system’s lack of readiness for full-scale implementation

01/ 07/ 2026

On 29 June, the European Business Association held a roundtable discussion dedicated to preparations for the implementation of the eExcise system. The event brought together market operators, representatives of the Ministry of Digital Transformation of Ukraine, the Ministry of Finance of Ukraine, the State Tax Service, the State Customs Service, as well as ELEKS, the developer of the system. Participants discussed the readiness of the eExcise functionality, the status of system integrations, and potential risks to the uninterrupted operation of the excise goods market following the planned launch. Business representatives noted that, as of the end of June, the eExcise system still lacks critical functionality. According to companies, both technical and legislative issues remain unresolved, despite the fact that businesses were expected to have approximately ten months to test the system. Market operators of excisable goods were therefore encouraged to actively participate in testing the system. At present, companies cannot confirm that the production, circulation, sale and fiscalisation of excisable goods will operate without disruption from 1 November. Among the key unresolved issues are the absence of an offline application and the lack of functionality for reflecting amendments to customs declarations, said Svitlana Mykhailovska, Deputy Director of the European Business Association. Participants stressed that any system failure after launch could have significant consequences for the state budget. According to business estimates, daily losses in excise tax revenues could exceed UAH 500 million. Following the discussion, the business community called on the authorities to: ensure that the system is fully ready for comprehensive testing involving businesses, the State Tax Service and the State Customs Service; urgently eliminate legislative gaps and inconsistencies that could hinder the launch of eExcise; prepare a contingency plan and the necessary legislative amendments in case the system is not ready by the scheduled launch date. Oleksandr Borniakov, Acting Minister of Digital Transformation of Ukraine, emphasised that the launch of eExcise remains one of the Ministrys key priorities. According to him, the Ministry does not intend to initiate any postponement of the systems launch and is focused on delivering a fully functional version to businesses for integration by the end of July. Oleksandr Zakusylo, Deputy Minister of Digital Transformation, added: eExcise is a complex digital reform involving several public authorities and the business community. We hear the concerns of businesses and, by the end of June, have already implemented a number of important improvements and system updates. In particular, businesses have completed comprehensive testing of the eExcise system and the full lifecycle of the electronic excise stamp, covering the movement of products from manufacturers or importers through distributors to retailers and consumers. We have also completed testing of business processes related to the calculation and payment of excise tax, which users will be able to test from early July. In addition, we will launch a dedicated support service platform in early July to ensure faster and more efficient processing of users requests. Representatives of ELEKS announced that businesses will receive a version of the system with a stable API in the second half of July. According to the company, the team has improved feedback collection and testing mechanisms, updated State Tax Service data, and will soon enable testing of excise tax payment processes. Testing of interactions between economic operators and the State Customs Service is also ongoing. The main business processes are expected to be tested jointly with companies throughout July and August. Anton Yelisieiev, Chair of the EBA Wine and Spirits Committee, stressed that alcohol importers urgently need access to a stable and functionally complete eExcise system capable of testing the entire supply chain—from import into Ukraine to sale to the end consumer. At present, the system does not provide this functionality, effectively preventing businesses from adequately preparing for mandatory implementation and creating significant risks for the uninterrupted operation of the entire industry once eExcise becomes compulsory. Nataliia Petrivska, Executive Director of UFRA, noted that although all system modules have been developed, eExcise still contains a considerable number of technical errors. The systems functionality continues to change and be updated, making it impossible for businesses to conduct high-quality testing while simultaneously developing and configuring their own IT solutions within the established timeframe. She also pointed out that the developer has not yet implemented offline testing functionality, which is critically important for market operators. Under these circumstances, there is a significant risk that the system will not be technically ready for full-scale launch and that excise market participants will not have sufficient time to complete integration and ensure full operational readiness by 1 November 2026. We call on the authorities to take all identified risks into account and facilitate the necessary actions to ensure a predictable and uninterrupted transition to the eExcise system. Moreover, given the renewed growth of the illicit tobacco market—according to the latest Kantar Ukraine study, which reached 19.8% in April this year—it is essential to avoid creating conditions that could further stimulate the illegal excise goods market, said Oksana Shvets, Deputy Director of the Strategic Development Department for European Integration at the American Chamber of Commerce in Ukraine. Nataliia Fesiun, Chief Executive Officer of Ukrtiutiun, recalled that businesses had consistently emphasised the need for a ten-month testing period during which eExcise would function as a complete and integrated system. This understanding between business and government was reflected in Law No. 3173-IX. However, this has not been achieved, as the system continues to undergo constant changes, preventing manufacturers from completing full integration. The government must ensure proper testing of the system, urgently eliminate legislative gaps and inconsistencies, and define a clear point of no return after which a contingency plan should be activated. Otherwise, from 1 November, the state budget risks losing UAH 500 million in tax revenues every day, she said. The European Business Association will continue to facilitate constructive dialogue between businesses and public authorities to ensure the timely and seamless implementation of the eExcise system.

On 29 June, the European Business Association held a roundtable discussion dedicated to preparations for the implementation of the eExcise system.

The event brought together market operators, representatives of the Ministry of Digital Transformation of Ukraine, the Ministry of Finance of Ukraine, the State Tax Service, the State Customs Service, as well as ELEKS, the developer of the system. Participants discussed the readiness of the eExcise functionality, the status of system integrations, and potential risks to the uninterrupted operation of the excise goods market following the planned launch.

Business representatives noted that, as of the end of June, the eExcise system still lacks critical functionality. According to companies, both technical and legislative issues remain unresolved, despite the fact that businesses were expected to have approximately ten months to test the system. Market operators of excisable goods were therefore encouraged to actively participate in testing the system.

“At present, companies cannot confirm that the production, circulation, sale and fiscalisation of excisable goods will operate without disruption from 1 November. Among the key unresolved issues are the absence of an offline application and the lack of functionality for reflecting amendments to customs declarations,” said Svitlana Mykhailovska, Deputy Director of the European Business Association.

Participants stressed that any system failure after launch could have significant consequences for the state budget. According to business estimates, daily losses in excise tax revenues could exceed UAH 500 million.

Following the discussion, the business community called on the authorities to:

ensure that the system is fully ready for comprehensive testing involving businesses, the State Tax Service and the State Customs Service;
urgently eliminate legislative gaps and inconsistencies that could hinder the launch of eExcise;
prepare a contingency plan and the necessary legislative amendments in case the system is not ready by the scheduled launch date.

Oleksandr Borniakov, Acting Minister of Digital Transformation of Ukraine, emphasised that the launch of eExcise remains one of the Ministry’s key priorities. According to him, the Ministry does not intend to initiate any postponement of the system’s launch and is focused on delivering a fully functional version to businesses for integration by the end of July.

Oleksandr Zakusylo, Deputy Minister of Digital Transformation, added:

“eExcise is a complex digital reform involving several public authorities and the business community. We hear the concerns of businesses and, by the end of June, have already implemented a number of important improvements and system updates. In particular, businesses have completed comprehensive testing of the eExcise system and the full lifecycle of the electronic excise stamp, covering the movement of products from manufacturers or importers through distributors to retailers and consumers. We have also completed testing of business processes related to the calculation and payment of excise tax, which users will be able to test from early July. In addition, we will launch a dedicated support service platform in early July to ensure faster and more efficient processing of users’ requests.”

Representatives of ELEKS announced that businesses will receive a version of the system with a stable API in the second half of July. According to the company, the team has improved feedback collection and testing mechanisms, updated State Tax Service data, and will soon enable testing of excise tax payment processes. Testing of interactions between economic operators and the State Customs Service is also ongoing. The main business processes are expected to be tested jointly with companies throughout July and August.

Anton Yelisieiev, Chair of the EBA Wine and Spirits Committee, stressed that alcohol importers urgently need access to a stable and functionally complete eExcise system capable of testing the entire supply chain—from import into Ukraine to sale to the end consumer. At present, the system does not provide this functionality, effectively preventing businesses from adequately preparing for mandatory implementation and creating significant risks for the uninterrupted operation of the entire industry once eExcise becomes compulsory.

Nataliia Petrivska, Executive Director of UFRA, noted that although all system modules have been developed, eExcise still contains a considerable number of technical errors. The system’s functionality continues to change and be updated, making it impossible for businesses to conduct high-quality testing while simultaneously developing and configuring their own IT solutions within the established timeframe.

She also pointed out that the developer has not yet implemented offline testing functionality, which is critically important for market operators. Under these circumstances, there is a significant risk that the system will not be technically ready for full-scale launch and that excise market participants will not have sufficient time to complete integration and ensure full operational readiness by 1 November 2026.

“We call on the authorities to take all identified risks into account and facilitate the necessary actions to ensure a predictable and uninterrupted transition to the eExcise system. Moreover, given the renewed growth of the illicit tobacco market—according to the latest Kantar Ukraine study, which reached 19.8% in April this year—it is essential to avoid creating conditions that could further stimulate the illegal excise goods market,” said Oksana Shvets, Deputy Director of the Strategic Development Department for European Integration at the American Chamber of Commerce in Ukraine.

Nataliia Fesiun, Chief Executive Officer of Ukrtiutiun, recalled that businesses had consistently emphasised the need for a ten-month testing period during which eExcise would function as a complete and integrated system. This understanding between business and government was reflected in Law No. 3173-IX. However, this has not been achieved, as the system continues to undergo constant changes, preventing manufacturers from completing full integration.

“The government must ensure proper testing of the system, urgently eliminate legislative gaps and inconsistencies, and define a clear ‘point of no return’ after which a contingency plan should be activated. Otherwise, from 1 November, the state budget risks losing UAH 500 million in tax revenues every day,” she said.

The European Business Association will continue to facilitate constructive dialogue between businesses and public authorities to ensure the timely and seamless implementation of the eExcise system.