Alcohol Sales with Delivery: What You Need to Know About Licenses, Cash Registers, and Age Verification

The conditions for selling alcoholic beverages to end consumers with delivery are defined by the Law of Ukraine No. 3817-IX. The State Tax Service clarified how these norms apply depending on the payment method and the involvement of courier services.

The law defines retail trade as the sale of goods directly to the end consumer for personal non-commercial use regardless of the payment method, including with delivery. Wholesale trade is considered the sale of alcoholic beverages to other business entities.

Retail sale of alcoholic beverages can only be carried out by business entities that have a valid retail trade license. For this, they must have a retail trade location equipped with a cash register or software cash register, and for the sale of alcoholic beverages (except for certain exceptions defined by law), the trading area of such premises must be at least 20 square meters.

Sellers are also obliged to comply with the requirements of Article 71 of Law No. 3817, in particular not to sell alcohol to persons under 18 years of age. If there are doubts about the buyer’s age, the seller or the courier delivering the goods must request an age verification document, including an electronic document via the "Diia" app.

The Tax Service also noted that e-commerce is carried out through online stores or other information and communication systems, and the buyer must receive a document confirming the conclusion of an electronic transaction and the purchase of goods.

To combat illegal alcohol sales online, the State Tax Service maintains a Register of licensed website addresses that conduct remote sales of alcoholic beverages, tobacco products, electronic cigarettes, and related products. The procedure for submitting information to this Register was approved by the Ministry of Finance order dated January 14, 2026, No. 34.

The State Tax Service explained that the retail seller is precisely the business entity that transfers alcohol to the end consumer and receives payment from the buyer, conducting a cash transaction for the full purchase amount. Such sales can also be carried out by a courier service if it has the necessary retail trade license, a retail trade location equipped with a cash register or software cash register, and complies with legislative requirements.

At the same time, if the seller transfers alcohol to the courier service, and payment is received not from the end buyer but from this courier service, such a transaction is no longer retail trade. In this case, it is the transfer of goods to another business entity, which requires the seller to have a wholesale trade license for alcoholic beverages.

Thus, alcohol sales with delivery are possible under two models.

If the buyer pays the courier service, the seller must have a wholesale trade license for alcoholic beverages, and the courier service must have a retail trade license, a retail trade location of at least 20 square meters equipped with a cash register or software cash register, and ensure compliance with age verification requirements.

If the buyer pays the seller directly, it is sufficient for the seller to have a retail trade license for alcoholic beverages, an appropriate trade location equipped with a cash register or software cash register, and to comply with the requirements of Article 71 of Law No. 3817 regarding the sale of alcoholic products.

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