Ukraine is drafting legislation to implement E-Audit, a new digital tax control model announced by the head of the Parliamentary Committee on Finance, Tax and Customs Policy, Danylo Hetmantsev. The software is already deployed within the State Tax Service environment, with user and administrator training underway. The Cabinet of Ministers plans to submit the draft law to Parliament by December 1, 2025, following completion of the IT system audit.
What E-Audit Does
-
SAF-T support: Businesses will submit Standard Audit File for Tax (SAF-T) files through the system.
-
Pre-check and validation: Automated checks verify data completeness and correctness before submission.
-
Risk visibility: Taxpayers can see identified risks and correct issues proactively.
How It Will Work
-
Automated risk analysis: Selection for inspections is algorithmic and transparent; only high-risk taxpayers are targeted.
-
Standardized inspections: Audit procedures become unified and data-driven, minimizing subjective decisions.
-
Reduced human factor: Decisions rely on machine analysis, limiting discretionary interference.
-
Faster VAT refunds: Automatic VAT refund within 5 days will be possible without a desk audit for low-risk taxpayers.
What It Means for Business
-
Fewer inspections for compliant firms: Low-risk companies should avoid documentary audits, reducing disruption and compliance costs.
-
Predictability and planning: Clear risk criteria and standardized processes improve cash-flow planning and audit readiness.
-
Lower administrative burden: SAF-T and automated validations streamline reporting and corrections.
-
Governance and controls push: Firms may need to upgrade ERP data quality, internal controls, and documentation to meet SAF-T and risk-model requirements.
Implementation Timeline
-
Now: System installed; training in progress.
-
By Dec 1, 2025: Government intends to submit the E-Audit bill to the Verkhovna Rada after the IT audit concludes.
-
Next steps: Parliamentary review, secondary regulations, phased onboarding of taxpayers, and calibration of risk models.
Practical Preparation Checklist for Companies
-
Map tax data to SAF-T structure; test extraction from ERP/accounting systems.
-
Run internal dry-runs through E-Audit validation checks to identify gaps.
-
Document key tax positions and maintain digital audit trails for invoices, inventory, and transfer pricing data.
-
Strengthen controls over VAT credits, reconciliations, and master data quality.
-
Assign an E-Audit owner (tax/finance lead) and train staff on workflows and response times.
Risks and Watchpoints
-
Model transparency: Monitor publication of risk criteria and appeal procedures.
-
Data security: Ensure robust cybersecurity and confidentiality for transmitted SAF-T files.
-
Change management: SMEs may require technical assistance to meet new digital standards.
-
Transitional overlaps: Clarify rules during the switch from legacy audits to E-Audit to avoid duplication.
Outlook
E-Audit is designed to make tax administration faster, fairer, and more transparent—targeting non-compliance while rewarding bona fide taxpayers with fewer audits and expedited VAT refunds. For compliant businesses, the reform should lower friction and uncertainty; for the state, it focuses resources on high-risk cases and strengthens revenue integrity.
