Starting in 2026, Ukraine will substantially narrow the scope of bank secrecy to fight tax evasion and bring rules in line with EU standards. Tax authorities will be able to obtain customer account information from banks under a formal request workflow and clearly defined grounds.
What Exactly Changes
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Access on request. The State Tax Service will be able to request data about balances, inflows/outflows, and specific transactions tied to an audit or risk signal.
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Broader perimeter. The rules apply to individuals and businesses, including private entrepreneurs.
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Alignment with international practice. The changes support automatic and on-request information exchange frameworks and AML/CTF compliance.
The Safeguards
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Legal basis & logging. Each request must cite a legal ground (audit, investigation, court decision, international exchange) and is logged.
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Data minimization. Banks provide only the scope specified in the request (no blanket “give everything”).
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Confidentiality & appeals. Unlawful disclosure can be appealed; misuse carries liability for officials.
What Banks Will Share (Typical Set)
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Identification data of the client and accounts
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Balances and turnover for a defined period
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Transaction details relevant to the case (counterparties, amounts, purpose)
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Supporting documents if expressly required by law or a court decision
Who Should Prepare Now
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SMEs and large corporates. Ensure bookkeeping and payment descriptions match real transactions; reconcile tax and bank data monthly.
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PE/VC-backed companies and high-growth startups. Clean up legacy accounts, close dormant cards, and document founder loans and intercompany transfers.
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Individuals with complex cash flows. Keep contracts and proofs for large incoming transfers (sales of assets, dividends, loans).
Practical Checklist (For 2025)
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Map accounts (company + founders) and close unused ones.
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Unify payment narratives: no vague “services” or emojis—use precise contract/article references.
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Match ledgers to statements monthly; fix gaps before the year-end close.
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Document equity & loans (board minutes, loan agreements, interest schedules).
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Refresh KYC files with your banks to avoid “suspicious activity” flags.
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Update privacy policies and employee onboarding to reflect the new regime.
Why It Matters for Investors
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Lower compliance risk for portfolio companies integrating with EU supply chains.
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Cleaner due diligence: verifiable cash-flow trails and less “key-person” dependency.
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Better credit access: transparent statements speed up lending and trade-finance approvals.
Bottom line: from 2026, “bank secrecy” won’t shield non-transparent flows. Treat bank statements as part of your tax archive—organized, explainable, and fully aligned with contracts and invoices.
