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New Tax Inspection Rules in Ukraine: Risk-Based Model Replaces Mass Audits

by Roman Cheplyk
Wednesday, August 6, 2025
2 MIN
New Tax Inspection Rules in Ukraine: Risk-Based Model Replaces Mass Audits

Moratorium on unjustified inspections shifts focus to digital analytics and high-risk sectors

New tax control algorithm: businesses will be inspected in a new way

Ukraine is launching a new tax control model focused on fairness, transparency, and risk prevention. Following a decision by the National Security and Defense Council and a Presidential Decree, a moratorium on unjustified inspections was introduced — but this does not mean a full stop to tax supervision.

Instead, the State Tax Service (STS) will implement a risk-based approach aimed at eliminating administrative pressure while identifying real violations.

✅ What changes for business

Under the new model:

  • Actual inspections will take place only if at least two risk indicators are present (or three for individual entrepreneurs in Groups I and II).

  • Scheduled inspections continue but use updated risk criteria, such as history of reporting, business transparency, and sector-specific patterns.

  • Small and medium-sized businesses (SMEs) under the simplified tax system and low-risk companies will be excluded from inspection plans.

  • High-risk industries — alcohol, tobacco, fuel, excisable goods — will be a priority for inspections.

🖥️ Focus on digital tax monitoring

The STS will now rely on digital tools and automated analytics, which:

  • Detect irregularities without inspector intervention.

  • Reduce the human factor and corruption risks.

  • Automatically flag risky behavior or suspicious transactions.

This transition marks a shift from punitive oversight to preventive analytics.

📊 Results already visible

  • 30% of current cases against businesses were reviewed and closed as baseless.

  • New amendments to the Criminal Procedure Code are being prepared to:

    • Prevent unjustified property seizures.

    • Stop illegal blocking of accounts without legal grounds.

🔍 Key goals of the reform

  • Build trust between the state and honest business.

  • Ensure protection from unlawful interference.

  • Target tax evasion schemes while promoting fair competition.


This tax reform is part of a broader modernization effort, aimed at aligning Ukraine’s business environment with EU standards and encouraging investment, transparency, and legal stability.

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