Blocking of tax invoices in 2026: the new risk criteria and how to restore registration
The State Tax Service has updated its taxpayer risk criteria. Registration of invoices is suspended more often, and the usual explanations no longer work. We set out the features that put a business on the risk list, which documents to file and within what deadlines in order to restore registration.
What has changed in the risk criteria
The updated list of risk features has moved the emphasis from formal indicators to the behaviour of counterparties. The commission now assesses not only the tax burden and the headcount, but the supply chain as well: if the chain holds a taxpayer bearing features of risk, your invoice may be suspended too.
In practice this means that checking a counterparty before the deal has become cheaper than unblocking invoices after it.
- A mismatch between the volumes of purchase and of supply under the UKT ZED codes
- The taxpayer has none of the fixed assets the declared transaction requires
- The counterparty was on the risk list on the date the invoice was drawn up
- The price of the transaction deviates from the market price by more than 30 per cent
Important. The deadline for filing explanations and copies of documents is 365 calendar days from the date the invoice was drawn up. A missed deadline cannot be restored, and the VAT stays in the unrecognised credit of the buyer.
How to restore registration, step by step
Obtain the receipt on the suspension. The receipt names the specific point of the criteria. From there we work with that point and not with the whole list.
Collect the primary documents on the transaction. The contract, the specifications, the consignment notes, the acts, the payment instructions and the evidence that the resource to perform it was there.
File the explanations through the Electronic Cabinet. Form J(F)1312603 plus scanned copies. One file per document, with its details in the name.
Follow the decision of the commission. Five working days. If it refuses, a complaint to the State Tax Service or a court claim, depending on the ground for the refusal.
What this means for business
Unblocking an invoice is not a dispute about the law, it is a dispute about evidence. It is won by the party whose primary documents describe a real business transaction and not only its result. That is why checking the counterparty and the completeness of the documents belongs in the process before the contract is signed.
