Business again calls for postponing implementation of e-Excise for at least 10 months due to system's unreadiness
By October 1, 2025, member companies of the European Business Association (EBA) called on the government and MPs to adopt legislative changes that would postpone the launch of the electronic system e-Excise and extend the system's test mode for at least 10 months (including the offline application, integration with software for payment transactions recorders and the full cycle of product circulation).
"According to Ukraine’s Law No. 3173-IX, the Electronic System for the circulation of alcoholic beverages, tobacco products, and e-cigarette liquids is scheduled to launch on 1 January 2026. However, as of today, the system’s functionality remains fragmented and far from being fully operational," the EBA reports.
Full testing of the e-Excise system was supposed to begin on 1 March 2025. Yet, not all secondary legislation regulating the system’s operation has been adopted, and software development is significantly delayed.
The testing period is reduced to just two months instead of the legally stipulated ten months. According to the business timeline provided by the Ministry of Digital Transformation, the Electronic System will only be ready for full-scale testing from November 2025, and the offline application, a critical component, will be available only from January 1, 2026, the date when the system is already supposed to be operational.
"The possibility of comprehensive testing of the Electronic System for at least ten months is crucial for preparing businesses for the new excise product traceability model. Market operators need sufficient time to adapt internal processes, integrate the required IT solutions, and conduct testing at all stages of the movement of excisable products, from producer or importer to consumer," the EBA reports.
From the beginning of next year, companies will be prohibited from importing excisable products with paper excise stamps or marking goods with them in Ukraine. Market participants have the last opportunity to order paper excise stamps by October 8, 2025 (two months before their receipt). There is also a risk that most importers will not manage to bring products into Ukraine with paper stamps, which they are expected to receive in December 2025.
Businesses have repeatedly raised this issue during working meetings and in public communication with government authorities, but it has yet to receive adequate attention. The alternative solution proposed by some state agencies, parallel operation of the e-Excise system alongside ordering and using paper excise stamps in the first half of 2026, is administratively complex and does not solve the problem, creating significant technical, logistical, financial, and legal risks for legitimate market operators.
It is emphasized that launching without proper preparation can lead to large-scale disruptions in the work of companies, a reduction in state budget revenues, and market destabilization.
In the event of non-acceptance of changes and deprivation of businesses of a full, legally prescribed, period for testing the system from the moment all its components are ready, this may lead to a temporary or complete cessation of the activities of companies from January 1, 2026, which, in turn, will affect supply chains, the stability of the functioning of industries related to the production, import and sale of alcoholic beverages and tobacco products.
The cessation of activities will also lead to losses for the state budget, which, according to preliminary calculations, may reach billions of hryvnias for each month of unstable market operation, which will lead to an explosive growth in the illegal circulation of alcoholic beverages and tobacco products in conditions of destabilization of the legal market, which will level all previous achievements of legal businesses in cooperation with law enforcement agencies in minimizing and overcoming the illegal circulation of excisable products.
