A Ukrainian company has more than one number, and they are constantly confused — not least by services promising to “check the VAT number”. Here is what is what.

The ЄДРПОУ code

Eight digits. Assigned when a legal entity is entered in the Unified State Register and fixed to it permanently: it does not change when the name, the director or the owner changes, and it is not reissued to anybody else after the company is terminated. It is the only number that identifies a company unambiguously in the open data, and it is what any check needs.

A sole trader (ФОП) has no ЄДРПОУ code; they are identified by their taxpayer registration number, which is personal data and is not published in the open datasets.

A VAT payer's individual tax number

Twelve digits. Assigned separately, by the State Tax Service, and only to those who have registered as payers of value added tax. It is the number printed on a tax invoice.

So: every legal entity has a ЄДРПОУ code; not every one has a VAT number. A company without one is not suspicious — it simply is not VAT-registered, which is entirely ordinary for a small business.

Why the open register does not carry it

Because it belongs to a different register. The Unified State Register is kept by the Ministry of Justice and publishes information about the legal entity; the register of VAT payers is kept by the tax service. A ЄДР record does carry a note of registration with the tax authorities — the taxpayer register and the unified social contribution register — but that is not the same as VAT registration, and the number itself is not there.

The tax service did publish a separate open dataset, the Register of value added tax payers. Its last update is 23 February 2022. The file can still be downloaded, it carries a CC BY licence, and it holds 36 megabytes of records — but it is a snapshot of the day before the full-scale invasion, not of today. Presenting it as a current status would mislead the reader, so we do not.

What about VIES?

VIES is the VAT Information Exchange System between European Union member states. Ukraine is not in it, so a Ukrainian VAT number cannot be checked through VIES — there is nothing there to answer. A service offering to do so is either checking another country's number or checking nothing.

Current VAT-payer status is shown only by the tax service's own e-cabinet. That is the one correct place, and no company directory — this one included — can replace it.

In short

  • ЄДРПОУ — 8 digits, open, every legal entity has one, never changes.
  • VAT payer number — 12 digits, absent from the open register, held only by VAT payers.
  • VIES — does not apply to Ukraine.