Card “key to the account”: what to consider when using

Card "key to the account": what is it?
Neither Regulation № 148 nor other regulatory documents defined what a “key to account card” is. But most recently, the NBU, in a letter dated 04.24.2019 № 57-0007 / 22460, explained the essence of such a banking product as the “key to the account” card, which is provided by AT “KB” “PrivatBank”. Based on the studied conditions and rules for provision of banking services by PrivatBank to NBU banking services, the NBU concluded that the card is “key to the account”: “is a banking product, in its functional properties, related to the corporate electronic means of payment by which its user has the right to initiate a transfer of funds from the current account in the manner specified by the contract and the requirements of the law. "

In other words, according to its functionality, the NBU regards the card as the “key to the account” as a corporate payment card. Accordingly, when using it, the same rules should be applied as when using a regular corporate card.
Unlike a PDA, the “key to the account” card provides direct access to the company's settlement account (i.e., the “2600” account). To get a "key card", you do not need to open an additional card account.
Although it is worth noting that "in practice" the card is the "key to the account" of AT "CB" "PrivatBank" often serves as a "substitute" for the check book for the enterprise. In addition, unlike conventional corporate cards, which can be issued by a bank for several employees, a “key to the account” card can be issued only to a person who has the right of first signature at the enterprise, that is, to the head of the enterprise. And can not be transferred to other persons.
What calculations can be carried out using the “key to the account” card of the company?
According to Regulation No. 705, users have the right to use electronic means of payment for carrying out payment transactions in accordance with the account regimes established by the regulations of the National Bank and the terms of the agreement with the issuer.
Previously, Instruction No. 492 established a number of restrictions on settlements using corporate payment cards. But from 04/04/2019 (the date when the new edition of Instruction No. 492 was earned) for conducting transactions from the accounts of business entities using the corporate payment card, there are no restrictions as such. There are restrictions on transactions in foreign currency: without limitations, it is possible to settle in one transaction day under one foreign economic agreement (contract), the operation for which does not exceed a minor amount, i.e. the equivalent of 150 thousand UAH.
However, in the same conditions and rules for the provision of banking services, AT “KB” “PrivatBank” stated (clause 3.4.1.18) that: “corporate payment cards are not used for receiving wages, other social payments, as well as for making settlements under foreign trade agreements (contracts) ".
Therefore, using the “key to the account” card, for example for issuing salaries, is not directly possible.
But there is still the possibility to send the funds for the payment of wages, withdrawn using the “key to the card” card. To do this, the director withdraws money from the card as if it were a business, after which, referring to the impossibility of executing the order given to him, on the basis of the “zero” advance report, returns them to the company's cash desk as unused advance. This money comes in the cash office of the enterprise (on the basis of PKO), and only then is issued as a salary.
If we are talking about settlements that are allowed to be directly carried out using the “key to the account” card (travel expenses, cash withdrawals for business expenses), then, as the NBU notes in the above-mentioned letter, the withdrawn money is used by natural persons - the company's authorized representatives without Pre-posting them at the box office. Thus, if the director, while on a business trip or buying something for the needs of the enterprise, “withdraws” the cash on the key to the card, then there is no need to pre-debit the cashier’s money that was withdrawn using the card. This is also spelled out in clause 20 of Regulation No. 148.
At the same time, let us pay attention once more: unlike the corporate card, the “key to the account” card can be issued only to the director. Therefore, it is not possible to “transfer” this card to other employees of the enterprise
Do I have to make an advance report when withdrawing or spending funds using the “key to the card” card?
Yes, sure. The National Bank of Ukraine draws attention to this in the above-mentioned letter № 57-0007 / 22460 of April 24, 2019. After all, the user of a corporate payment card can only be a business entity - an enterprise. Therefore, as soon as the director withdraws the money using the “key to the abacus” card or pays for the goods / services purchased with it, all of his further actions must follow the rules prescribed for reporting.
The date of issue of the money under the report to the card holder will not be the date of transfer of the card to him, but the date of withdrawal of funds from it.
Moreover, the terms and conditions of the provision of banking services by AT “KB” “PrivatBank” are also indicated (clauses 3.4.1.19) that: “funds withdrawn from the account of a legal entity or an individual entrepreneur in transactions that were carried out from the use of electronic means of payment shall be deemed issued under the report to the holder of the electronic means of payment. "
Therefore, after the director removes / spends money using the “key to the card” card, he must:
1) to submit an advance report - Report on the use of funds issued for a business trip or a report (even if the withdrawn amount is not spent). And, of course, attach to the Report a document that confirms the use of the card for cashless settlements (receipt of payment terminal, ATM check, slip, receipt of trading terminal, etc.), as well as a settlement document (cash receipt, sales receipt, settlement receipt, etc.), which confirms the purchase of goods, the provision of services;
Even in the case of "cashless" purchases using the card "key to the account" to make an advance report necessarily.
2) return the unused balance before or during the submission of the advance report.
What is the deadline for the advance report?
The advance report must be submitted (paragraphs 170.9.2 and 170.9.3 of the GCC):
- if cash was withdrawn with the help of the card - until the end of the 3rd banking day after a business trip or the 5th banking day following the day in which the employee completes the execution of a separate civil action. In the same time the tax authorities (category 103.17 ZIR) insist that the 3-day restriction works in both the first and second cases;
- if payments were made using a card in a cashless form - within 10 banking days upon completion of the transaction.
Is it possible directly to the company's current account (through the bank’s cash office), bypassing the enterprise’s cash office, to credit the unspent cash balance withdrawn using the “key to the account” card?
Paragraph 170.9.2 of the TCU says that if there are unnecessary funds, their amount is returned by the taxpayer to the cashier or credited to the bank account of the person who issued them, before or during the filing of the specified report. However, it is worth considering that the NBU in a letter dated January 11, 2019 No. 50-006 / 1765 with reference to clause 20 of Regulation No. 148 indicated that the unused cash balance along with the advance report should be deposited in the company's accounting department.
The “key to the card” card is used to withdraw money during the day several times. Is this considered a single issue of funds under the report (for the restriction under paragraph 19 of Regulation No. 148)?
Clause 19 of Regulation No. 148 establishes a ban on issuing cash to an accountable person while such a person has not reported on funds received earlier under the report. This rule also applies to the receipt of funds on the “key to the account” card. However, this “restriction” takes effect only after the deadlines for submitting an advance report on the funds used have already come. As long as these deadlines have not been reached, the director may still withdraw money from the card.