A systemic problem: why the de-shadowing of tobacco and alcohol markets is delayed
14 November 2025 13:33
ANALYSIS FROM 
The launch of the Electronic System for Controlling the Turnover of Excisable Goods is delayed. As you know, the eTax system is supposed to replace the current paper excise stamps with electronic ones with unique codes. This would allow the controlling authorities to constantly monitor excisable goods and help reduce the shadow market and increase budget revenues. But all this will have to wait. We found out why this happened
The Ministry of Finance and other relevant government agencies have finally agreed to postpone the introduction of the electronic excise stamp and the Electronic System for Controlling the Circulation of Alcohol, Tobacco Products and E-Cigarette Liquids by 10 months, from January 1 next year to November 1. And this happened not only due to the persistence of specialized business associations and key market operators, who held more than one meeting and made more than one statement on this issue. The government officials simply recognized the obvious: both the control system and the market are not yet ready for the transition to the eAccounting Stamp.
Business warned
Over the past few months, business representatives have repeatedly explained why it is worth waiting with the eAccounts.
Most recently, in mid-October, the European Business Association once again emphasized that the functionality of the Electronic Control System remains fragmented and far from being fully operational.
“The full testing of the eAcquis system was supposed to start on March 1, 2025. However, all the bylaws that should regulate the operation of the Electronic System have not yet been adopted, and the software development is significantly delayed. In fact, the test mode is reduced to 2 months instead of the 10 months required by law,” the EBA stated, insisting on postponing the launch of eAcces and extending the test mode of the Electronic System for at least 10 months.
If the business is deprived of full testing of the Electronic System, the EBA warned, it could lead to
– temporary or complete shutdown of legal business activities;
– significant losses to the state budget due to a shortfall in excise tax revenues and other mandatory payments;
– explosive growth of the illegal circulation of alcoholic beverages and tobacco products in the context of destabilization of the legal market, etc.
The Ukrtiutiun Association also pointed to the unpreparedness of the e-excise system and the risks associated with it.
“If the system is launched on January 1, 2026, without proper testing of all its components and stable access to the full functionality, as well as improvement of legislative regulation, there is a risk of disruptions in the supply of legal products, growth of the shadow market and significant losses to the state budget. According to preliminary estimates, this is UAH 400 million daily,” the business representatives emphasized.
The demand addressed to government officials was simple: to ensure the possibility of testing and proper implementation of a full-fledged eAccounts system.
Problems of the system
Why were there such delays in the development and implementation of the Electronic System for Controlling the Circulation of Alcohol, Tobacco Products and E-Cigarette Liquids? Source
It is also worth mentioning that the international IT company Eleks was engaged in the development of the electronic system for the circulation of alcoholic beverages and tobacco products following a tender held by the Eastern Europe Foundation. As reported, Eleks is a company with a staff of more than 2,000 specialists, headquarters in Tallinn, offices in 20 countries, and extensive experience in software development and consulting.
In its response to the request, the Ministry of Digital Transformation, of course, took the opportunity to talk about what it had done and listed a fairly large number of key functions available as of September 2025 for testing in the Electronic System.
The Ministry of Digital Transformation also explained that the system is being implemented in a continuous development format. This is when each component is tested, finalized and gradually opened to users.
“This approach is a standard international practice for complex IT solutions that work with critical business information. Since the launch of the Electronic System, we have been constantly interacting with representatives of economic operators, executive and legislative authorities: a significant number of proposals have been collected, some of which have already been taken into account when updating the system’s functionality,” the Ministry said.
They added that such a phased approach is combined with open feedback channels, which allows for a prompt response to challenges and ensures the quality development of the Electronic System by the time it is launched with full functionality.
The Ministry of Digital Transformation also tried to explain the reasons that affected the timing of the development and implementation of the Electronic System. First of all, it is the problems with financing.
“The design, development, and implementation of the Electronic System was planned with the financial and expert support of the International Technical Assistance Project “Support for Digital Transformation” (DTA Project). However, due to the US Presidential Decree of January 20, 2025 “Reassessment and Reorientation of United States Foreign Assistance” and based on the decision of the United States Agency for International Development (USAID) of March 12, 2025, the DTA Project was suspended. This led to the temporary suspension of development funding and the need to revise the schedule for the development, testing and implementation of the Electronic System,” the Ministry of Digital Transformation explained, adding that funding from two other international technical assistance projects was attracted to continue the work.
Another reason for the delay in developing the full functionality of the Electronic System is “the lack of access to the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Organizations in January-February 2025 and to its test environment until mid-May 2025, caused by a cyberattack on the information systems of the State Enterprise National Information Systems. As a result, there is again a need to amend the schedule for the development of the Electronic System, including the test mode.
The Ministry of Digital Transformation believes that it has responded appropriately to the above challenges.
“The Ministry of Digital Transformation of Ukraine has taken exhaustive measures to respond to the circumstances related to changes in funding, cyberattacks and the long adoption of regulations by other central executive authorities necessary to ensure the proper functioning of the Electronic System in 2026,” the Ministry said in a response to our publication.
But not everyone agrees with this assessment.
The cost of delay
The Ministry of Finance has already proposed legislative changes that would postpone the introduction of the electronic excise tax stamp and the Electronic System for the Circulation of Alcoholic Beverages, Tobacco Products and E-Liquids for Electronic Cigarettes to November next year. The Parliamentary Committee on Finance, Taxation and Customs Policy has already recommended that the Verkhovna Rada support this decision.
At the same time, the Chairman of the Committee, Danylo Hetmantsev, was quite categorical in his assessment.
“We recommended the Verkhovna Rada to extend the deadline for the implementation of the e-excise reform, which was disrupted by the Ministry of Digital Transformation this year. The deadline has been postponed to 11/1/26, which means that the de-shadowing of the tobacco and alcohol markets is being slowed down,” the MP wrote in his Telegram.
It is worth recalling here that the market of excisable goods – alcohol, tobacco and fuel – is considered the most “shadowy” in Ukraine. And Danylo Hetmantsev constantly mentions unshadowing as one of the main reserves for filling the budget.
He also said that at the same time, the Cabinet of Ministers of Ukraine was recommended to “make a decision on disciplinary action and consider the suitability of the First Deputy Minister of Digital Transformation Oleksiy Vyskub, who is responsible for the implementation of the E-excise and is guilty of delaying the launch of the Electronic System for the Circulation of Alcoholic Beverages, Tobacco Products and Liquids Used in Electronic Cigarettes.”
According to the deputy, “this will continue until the official is personally responsible for his or her own inaction.”
Author: Sergiy Vasilevich
