Which law applies
First, a trap that makes some recent articles online describe rules that do not exist yet. In 2023 the Verkhovna Rada adopted a new Law 'On Consumer Protection' No. 3153-IX. It enters into force one year after publication, but not before martial law is ended or lifted. On 24 October 2026 the law's card on zakon.rada.gov.ua shows the status 'entering into force'.
So an online shop today works under the old Law No. 1023-XII (status 'in force', version of 24.12.2024). All the consumer rules below come from it. Alongside it apply the Law 'On Electronic Commerce', the Civil Code and Law No. 265/95-VR on cash registers.
When a site makes an offer
Article 641 of the Civil Code separates two cases. Information on the internet that contains the essential terms of a contract and a proposal to conclude it with anyone who applies is an offer. Advertising and other proposals to an indefinite group of people are only an invitation to make offers, unless they say otherwise.
The practical consequence for a shop: if the site has a 'Public offer' page with terms of sale, payment, delivery and returns, and the buyer clicks 'Place order', the contract is concluded on those terms. The Law on Electronic Commerce (Article 11) allows terms from another document to be included by a link if the buyer could read it. So the link to the offer belongs next to the order button, not only in the footer.
Retail is a public contract under Article 633 of the Civil Code: the terms are the same for all consumers, except those with statutory benefits, and the business may not refuse a buyer when it has the goods. Individual 'just for you' terms in an offer contradict this rule.
Checklist: what, where and under which rule
The table is compiled from Articles 7 and 11 of the Law on Electronic Commerce, Articles 13 and 15 of Law No. 1023-XII and Articles 27 and 30 of the State Language Law. The 'Where' column is the minimum place the rule requires.
| What | Where | Rule |
|---|---|---|
| Full name of the company or sole trader, location (for a sole trader, place of registration and actual residence), e-mail or shop address, company code or individual tax number | On the site, with direct and stable access | E-commerce, Art. 7(1) |
| Licence (series, number, term, date), if the activity is licensed | On the site | E-commerce, Art. 7(1) |
| Price including delivery, payment terms, whether taxes are included | Before the order | E-commerce, Art. 7(1); No. 1023-XII, Art. 13(2) |
| Main characteristics of the product | Product page, before the order | No. 1023-XII, Art. 13(2), Art. 15 |
| Warranty, service, how complaints are accepted | Before the order and in the confirmation | No. 1023-XII, Art. 13(2); e-commerce, Art. 11(11) |
| Exchange and return terms, how to terminate the contract | In the offer and in the confirmation | No. 1023-XII, Art. 13(2); e-commerce, Art. 11(11) |
| Delivery period; if not stated, no later than 30 days | In the offer | No. 1023-XII, Art. 13(6) |
| Clause on replacing an out-of-stock item with another | In the offer, before the order | No. 1023-XII, Art. 13(6) |
| Ability to correct entered data before clicking the order button | Order form | E-commerce, Art. 11(8) |
| Prompt acknowledgement that the order was received | E-mail or message to the buyer | E-commerce, Art. 11(7) |
| Ability to get the offer in a form that cannot be altered (for example, PDF) | Offer page | E-commerce, Art. 11(7) |
| Ukrainian: the offer, product information, the default version of the site | The whole site | E-commerce, Art. 11(14); language law, Art. 27(6), Art. 30 |
The row most often missed is the confirmation e-mail. Shops send 'Thank you, your order No. 1234 has been received' and stop there. But the content of that e-mail decides how many days the buyer has to return the goods.
Returns: 14 days or 90
Article 13 of Law No. 1023-XII on distance contracts requires information about the seller, the product, price, warranty, delivery terms and how to terminate to be confirmed in writing or by electronic message. Information confirmed this way cannot be changed by the seller unilaterally.
- Is the item among the exceptions of Article 13(5)?Made to the buyer's order, an opened sealed recorded medium, periodicals, lotteries, a price tied to market quotes. Yes → no withdrawal right under Article 13, unless the contract says otherwise
- Did the buyer receive a confirmation with the information under Article 13(2)?Seller, characteristics, price with delivery, warranty, delivery terms, how to terminate, in writing or by e-mail. No → 90 days from receiving the goods
- Was the confirmation corrected later?For example, an e-mail with all items was sent after delivery. Yes → 14 days from receiving the corrected confirmation
- Is the confirmation complete?The period runs from the confirmation or from receipt of the goods. Yes → 14 days
Separately, there is the right to exchange goods of proper quality under Article 9: 14 days, not counting the day of purchase, if the item did not fit by shape, size or colour. The list of goods that cannot be exchanged is approved by Cabinet Resolution No. 172: food, medicines, perfumery, underwear, hosiery, printed matter and others. The resolution refers to the Article 9 exchange right. Whether the list also covers withdrawal from a distance contract under Article 13 the law does not say directly; Article 13 has its own list of exceptions. We draw no conclusion here: for underwear or cosmetics, agree the wording in your offer with a lawyer.
Eight common mistakes in offers
| What the offer says | What the rule says |
|---|---|
| 'The buyer pays for return shipping' | Any costs related to the return are borne by the seller (No. 1023-XII, Art. 12(5); for distance contracts via Art. 13(7)) |
| 'Returns only in undamaged packaging' | A loss of value from opening the packaging, inspecting or testing does not remove the right to terminate (Art. 12(7)). The goods must be kept unchanged |
| 'Discounted items cannot be returned' | Discounts are not among the exceptions of Art. 13(5) |
| '14 days from the order date' | The period runs from the confirmation of information or from receipt of the goods (Art. 13(4)) |
| 'The price may change after ordering' | Confirmed information, including the price, cannot be changed unilaterally (Art. 13(3)) |
| No seller details on the site, only a brand name | Name, location and company code or tax number are mandatory (e-commerce, Art. 7(1)) |
| 'Disputes are interpreted in the seller's favour' | Unclear terms of consumer contracts are interpreted in the consumer's favour; unfair terms can be declared invalid (No. 1023-XII, Art. 18) |
| 'Card payment, no receipt needed' | A receipt is issued to the person who receives or returns goods, including goods ordered and paid for online (No. 265/95-VR, Art. 3(2)) |
The first mistake is the most expensive by number of cases: every return the buyer paid for can become a complaint. Below is what a refusal leads to.
What a mistake costs
Penalties are set by Article 23 of Law No. 1023-XII and Article 17 of Law No. 265/95-VR. The tax-free minimum income for the purposes of other laws is UAH 17 under the Tax Code (Section XX, Subsection 1, item 5), so five minimums are UAH 85.
A hypothetical example: an item priced at UAH 1,200.
Exchange refusal: ten times the price, at least UAH 85 (Art. 23(1)(1), No. 1023-XII). Receipt: 100% of the sale the first time, 150% for repeats (Art. 17(1), No. 265/95-VR). Delay: a penalty of 1% of the price per day payable to the buyer (Art. 12(9), No. 1023-XII). The item price is hypothetical; checked on 24.10.2026.
Missing mandatory information about the product or seller is penalised under item 7 of the same Article 23: 30% of the value of the batch of goods received for sale, but at least UAH 85. How an inspector determines the 'batch' for an online shop with a permanent range the law does not specify, so we do not calculate an amount. Article 13 does not directly name the refund deadline after withdrawal from a distance contract; to avoid disputes about delay, write it into your offer.
Fiscal receipts on sale and return
Paying by card on the site does not remove the receipt. Article 3(2) of Law No. 265/95-VR requires a receipt for the person who receives or returns goods, including those ordered or paid for online. The receipt may be electronic: by phone, e-mail or a QR code. Returns are also processed with a receipt.
Single-tax payers of group 1 are exempt from software cash registers (item 296.10 of the Tax Code). For services there is an exception when payment goes exclusively through online banking or money transfer services (Article 9(14) of Law No. 265/95-VR); there is no such exception for goods. A full breakdown with a decision tree and ways to fiscalise payments automatically is in the article on online acquiring. Cash on delivery has its own economics of refusals; we calculated it separately.
Our position
The most useful step is not a new offer template but a confirmation e-mail with every item of Article 13(2): without it the return period is 90 days instead of 14, and terms the buyer did not receive in writing are hard to prove. The second most important step is to remove the 'returns at the buyer's expense' clause: the text of Article 12 puts these costs on the seller. Build them into your unit economics, as we did in the article on the first year of an online shop.
The position stops holding on the day Law No. 3153-IX enters into force: it changes consumer rules, and the checklist will need to be checked again. It also does not cover business-to-business sales (contracts with sole traders and companies are not consumer contracts) or goods made to the buyer's order. For underwear, cosmetics, medicines and food, agree the return wording with a lawyer.
Checked on 24 October 2026 on zakon.rada.gov.ua against the texts and cards of Laws No. 1023-XII and No. 3153-IX, 'On Electronic Commerce', No. 265/95-VR, 'On Ensuring the Functioning of Ukrainian as the State Language', the Civil and Tax Codes and Cabinet Resolution No. 172. The arithmetic was recalculated in code. The item price in the example is hypothetical. This article is not legal advice.