As of August 2026, SAF-T UA is filed only by large taxpayers and only at the request of the tax authority during a documentary tax audit, no later than two working days after the day the request is received (Article 85.2 of the Tax Code of Ukraine, ПКУ). Current legislation provides for no regular annual filing, and small businesses and sole proprietors (ФОП) are outside the obligation.
Legal basis: where the obligation comes from
The obligation has two levels: the Tax Code provision and the Ministry of Finance's technical procedure. Article 85.2 of the Tax Code of Ukraine (Code No. 2755-VI of 2 December 2010) requires a large taxpayer, at the tax authority's request, to provide the authority's officials, electronically and by electronic means of communication, with copies of documents on the accounting for income, expenses and other indicators relevant to determining taxable items, primary documents, accounting registers and financial statements, no later than two working days after the day the request is received.
The technical framework is set by the Procedure for a Large Taxpayer to Provide Documents in Electronic Form During a Documentary Tax Audit, approved by Ministry of Finance Order No. 1393 of 7 November 2011 (registered with the Ministry of Justice of Ukraine on 16 January 2012 under No. 44/20357); the current version dates from 27 August 2021 and has the status "In force". The concept of the standard audit file was added to the Procedure by Ministry of Finance Order No. 561 of 15 September 2020 (registered with the Ministry of Justice on 12 November 2020 under No. 1123/35406). That order introduced the XML format and replaced the terminology of the digital signature with the qualified electronic signature and seal. It came into force nine months after its official publication, which is why the current version of the Procedure has applied since 27 August 2021.
Under the definition in section III, paragraph 3.2 of Procedure No. 1393, SAF-T UA is an electronic file with a standardised XML structure containing data exported from the source accounting system on the existence and condition of assets, equity and liabilities, and information on changes in the entity's financial and business position over a given period.
Who must file and how to check your status
The obligation depends solely on large taxpayer status. Under subparagraph 14.1.24 of Article 14.1 of the Tax Code, a large taxpayer is a legal entity or a non-resident's permanent establishment whose income from all activities over the last four consecutive tax (reporting) quarters exceeds the equivalent of EUR 50 million, or whose total taxes, levies and payments to the State Budget of Ukraine (excluding customs payments) exceed the equivalent of EUR 1.5 million, at the NBU's weighted average official exchange rate for the same period. A sole proprietor cannot be a large taxpayer by definition, so the SAF-T UA obligation does not apply to them.
The difficulty is that you cannot check yourself against a public list. After applying its "three-part test", the State Tax Service (ДПС) concluded that under martial law information from the Register of Large Taxpayers is not to be published. A self-check procedure:
- wait for and check the State Tax Service notice of inclusion in the Register: under the Procedure for Compiling the Register of Large Taxpayers (approved by Ministry of Finance Order No. 911 of 21 October 2015, registered with the Ministry of Justice on 9 November 2015 under No. 1395/27840), the Register for the next calendar year is approved by a State Tax Service order by 22 October of the current year, and inclusion notices are sent by 1 November. This notice is the practical confirmation of status;
- bear in mind that large taxpayers not registered with the State Tax Service units that handle large taxpayers must file an application in form No. 1-OPP no later than 1 December (section III, paragraph 3 of Procedure No. 911);
- bear in mind that the obligation to register with such a unit arises from the start of the tax period (calendar year) for which the Register was compiled (Article 64.7 of the Tax Code);
- check your own figures for four consecutive quarters against the thresholds of EUR 50 million in income or EUR 1.5 million in taxes paid;
- in a group of companies, check each legal entity separately: the status is not passed on within the group.
If your figures are approaching the thresholds, build SAF-T UA preparation into your accounting development plan well in advance, together with the organisation of your accounting: the quality of the primary data decides whether a valid file can be produced at all.
When the file is filed: myths and the law in force
SAF-T UA is an on-demand tax control tool; it has not become a new regular report. The confusion comes from Draft Law No. 6255 "On Amendments to the Tax Code of Ukraine to Introduce Electronic Audits (E-Audit)", submitted by the Cabinet of Ministers on 2 November 2021. It would have required the file to be filed every year within 60 calendar days after the reporting year, introduced separate fines and gradually extended the obligation to taxpayers defined in Article 180 of the Tax Code. According to the bill's page on the Verkhovna Rada portal, it was withdrawn on 17 July 2025 with the status "Removed from consideration", and no new bill has been submitted to parliament.
Common claims about SAF-T UA and the rules in force in 2026
| Claim often made in advisory materials | What the law says in 2026 |
|---|---|
| The file is filed every year within 60 calendar days after the reporting year | Filing is only on request during an audit, with a two-working-day deadline (Article 85.2 of the Tax Code); the 60-day rule was in Draft Law No. 6255, withdrawn on 17.07.2025 |
| The fine for failing to file is 100 minimum wages | The Tax Code has no such penalty: 100 minimum wages for large taxpayers (and 10 for taxpayers under Article 180 of the Tax Code) was proposed in the withdrawn Draft Law No. 6255. The general rules of Article 121 of the Tax Code apply |
| From 2027 SAF-T UA is mandatory for all VAT payers | The Tax Code contains no such rule: an obligation from 1 January 2027 for taxpayers defined in Article 180 of the Tax Code was only a proposal in the withdrawn Draft Law No. 6255 |
| Filing SAF-T UA replaces providing documents for the audit | No: the obligation to provide officials with all documents belonging to or related to the subject of the audit in full remains (Article 85.2 of the Tax Code) |
File format and structure
The file is generated in XML and has a strictly defined structure, set out in the appendix to Procedure No. 1393. It covers: section I, Header, with general data about the taxpayer and the file; section II, MasterFiles: accounting policy, transaction type lists, owners (founders), trial balances, counterparties, products, inventories and non-current assets; section III, GeneralLedgerEntries; section IV, SourceDocuments: sales, purchases, payments, inventory and non-current asset transactions, and accounting memoranda; and a TaxDifferences section.
The updated version 2.0 of the SAF-T UA file was published on the State Tax Service web portal on 6 November 2024. As the State Tax Service explained in its clarification of 10 February 2026, this is why 2024 is the first calendar year for which the tax authority may request documents in the form of a SAF-T UA file. The "XSD (XML schema definition for the SAF-T UA standard audit file)" tab on the State Tax Service web portal contains schemas for several versions, from 1.1 to 2.0, together with the Detailed Technical Description of SAF-T UA Elements and its appendices. Before your first export, check which version your accounting module produces: an outdated schema is a common reason for rejection.
Technical requirements for the SAF-T UA file
| Parameter | Requirement under Procedure No. 1393 and State Tax Service clarifications |
|---|---|
| Data format | XML in the form of a standard audit file (SAF-T UA) |
| Periods longer than a calendar year | a separate file for each year: four files are produced for the period 01.01.2022–31.03.2025 |
| Upload method | a zip archive or a group of archives, separately for each reporting (tax) period stated in the request |
| Technical check | unpacking and checking the file against the XSD schema |
| Logical check | data validation, after which a second receipt listing any errors is generated |
| Signing and protection | qualified electronic signature and seal, encryption before sending (paragraphs 3.3–3.4 of Procedure No. 1393) |
Filing procedure and what to do if the file is rejected
The file is filed through the private section of the Electronic Taxpayer Account. According to the State Tax Service clarification of 22 April 2026, the taxpayer opens "Incoming / Outgoing documents" → "Incoming", finds the tax authority's request and uses the "Create SAF-T UA file" function to upload the prepared file, separately for each period stated in the request, as a zip archive or a group of archives. After upload, the file is unpacked and checked against the XSD schema; if it passes, an electronic signature is applied and the file is sent to the State Tax Service for automated processing. The taxpayer then receives a second receipt confirming that the file was accepted or rejected, with a list of the errors found. If the file is rejected, the causes must be fixed and the file sent again (section III, paragraph 3.7 of Procedure No. 1393), which is why testing in advance is so important.
What changed in 2025–2026
The main news of the period is that the State Tax Service's E-Audit information and communication system has been in full operation since 31 December 2025. The State Tax Service recorded the first practical use of SAF-T UA in a documentary audit on 4 September 2025 (an audit relating to a VAT refund), and on 24 October 2025 it reported the first test file filed without FE or RE type errors. As of 20 April 2026, the State Tax Service reported that in the first quarter of practical use of E-Audit it had received 14 SAF-T UA files directly from taxpayers in response to tax authority requests during documentary audits.
The format itself was developed with reference to the OECD Guidance on the Standard Audit File – Tax (Version 2.0), and the State Tax Service introduced electronic audit in cooperation with the EU4PFM project.
Since 3 March 2026, large taxpayers have been able to test their SAF-T UA file before receiving an official request by sending it through the Electronic Taxpayer Account. Formally, the system does not accept such a file: the taxpayer receives a notice of non-acceptance because there is no tax authority request, but together with it receives information on any technical errors or shortcomings found. The State Tax Service recommends combining this testing with checking the readiness of accounting and information systems, bringing the file structure into line with Procedure No. 1393 and the Detailed Technical Description of SAF-T UA Elements, and updating internal procedures for responding to requests.
Penalties: what failing to file really costs
The Tax Code contains no separate penalty specifically for failing to file SAF-T UA, and this often misleads people. The general rules of Article 121 of the Tax Code apply. For failing to provide the tax authorities with original documents or copies during tax control in the cases provided for by the Code, Article 121.1 sets a fine of UAH 1,020, rising to UAH 2,040 for the same breach by a taxpayer already fined for the same breach within the year. If documents or information are not provided in response to a tax authority request under Article 73 of the Tax Code, Article 121.2 applies: one minimum wage, as set by law on 1 January of the tax (reporting) year, for each such breach, and five minimum wages for requests under items 6–8 of subparagraph 73.3.1 of Article 73.3. In 2026 the monthly minimum wage is UAH 8,647 (Article 8 of the Law of Ukraine "On the State Budget of Ukraine for 2026" No. 4695-IX of 3 December 2025). Paying these fines does not release the taxpayer from the obligation to provide the information.
A much greater risk lies elsewhere. Under Article 44.6 of the Tax Code, if the taxpayer does not provide documents supporting the figures in its tax returns before the end of the audit, those documents are treated as missing at the time the returns were prepared, with the resulting additional tax assessments. For a large taxpayer these amounts are of a different order from any of the fines above, so it is logical to treat SAF-T UA preparation as part of tax risk management, alongside a tax audit of the company.
Does this affect small businesses?
No. As of August 2026, small businesses and sole proprietors are outside SAF-T UA: the obligation is tied solely to large taxpayer status, and only a legal entity or a non-resident's permanent establishment can have that status (subparagraph 14.1.24 of the Tax Code). The idea of extending the obligation to taxpayers defined in Article 180 of the Tax Code (that is, VAT payers) from 1 January 2027 appears only in the withdrawn Draft Law No. 6255 and creates no obligation without amendments to the Tax Code.
How to prepare: a 6–12 month plan
Preparation starts with a data quality review. The State Tax Service's question-and-answer clarifications show where accounting systems most often fail to provide the required level of detail:
- transactions must be split by the first event for all purchases and sales of goods, works and services, whatever internal classification of transaction types the company uses;
- the accounting policy is submitted in table form as separate elements, with the details of the order (orders) on accounting policy and the standards applied, Ukrainian national standards (П(С)БО) or IFRS, and must reflect all the information set out in those orders;
- accounting entries must show the corresponding accounts, and the tax information in the source documents section must match the tax information in the accounting entries section.
A sensible sequence: a data review and mapping of each SAF-T UA section to its source in the accounting system → updating the export module to XSD v2.0 → a trial file for one quarter → a test submission in the Electronic Taxpayer Account and analysis of the receipt → a procedure for responding to a request within two working days, with clear roles (who receives the request, generates the file, signs it with the qualified electronic signature and checks the result). For companies applying international standards, consistency between the file and the IFRS financial statements needs particular attention: discrepancies in the figures surface at the logical check stage.
Frequently asked questions
Does SAF-T UA have to be filed every year?
No. Current legislation does not provide for regular annual filing: the file is provided only at the request of the tax authority during a documentary audit (Article 85.2 of the Tax Code). The rule about 60 calendar days after the reporting year was in Draft Law No. 6255, which was withdrawn and removed from consideration on 17 July 2025.
What is the fine for failing to file SAF-T UA in 2026?
The Tax Code has no penalty specific to SAF-T UA; the general rules of Article 121 apply. For failing to provide documents during tax control, Article 121.1 sets a fine of UAH 1,020, or UAH 2,040 for a taxpayer already fined for the same breach within the year; for failing to provide documents or information in response to a tax authority request under Article 73, Article 121.2 sets one minimum wage per breach (UAH 8,647 in 2026). Paying the fine does not release the taxpayer from the obligation to provide the information, and under Article 44.6 of the Tax Code, documents not provided by the end of the audit are treated as missing at the time the returns were prepared.
Does SAF-T UA apply to sole proprietors and small businesses?
No. The obligation applies only to large taxpayers, and under subparagraph 14.1.24 of the Tax Code only legal entities and non-residents' permanent establishments can be large taxpayers, so a sole proprietor can never be one. Extending the obligation to taxpayers defined in Article 180 of the Tax Code was proposed only in the withdrawn Draft Law No. 6255.
How can a company find out whether it is a large taxpayer for 2026?
The practical confirmation of status is the State Tax Service notice of inclusion in the Register of Large Taxpayers: under the Procedure approved by Ministry of Finance Order No. 911 of 21 October 2015, the Register for the following year is approved by a State Tax Service order by 22 October, and notices are sent by 1 November. Under martial law the list of taxpayers itself is not published. The obligation to register with the unit that handles large taxpayers arises from the start of the calendar year for which the Register was compiled (Article 64.7 of the Tax Code). In addition, check your figures for four consecutive quarters against the thresholds of EUR 50 million in income or EUR 1.5 million in taxes paid.
How long does a company have to file SAF-T UA after a tax authority request?
Two working days after the day the tax authority's request is received during a documentary audit; this deadline is set directly by Article 85.2 of the Tax Code. If the file is rejected at the technical or logical check, the causes must be fixed and the file sent again.
Which SAF-T UA XSD version should be used in 2026?
The current schema is SAF-T UA version 2.0, published on the State Tax Service web portal on 6 November 2024. The same page has the schemas of earlier versions, the Detailed Technical Description of SAF-T UA Elements and its appendices. Before generating the file, check which version your accounting module produces, because an outdated schema leads to rejection.
This article reflects the position as of August 2026. If your company is a large taxpayer or is approaching that status, we can assess how ready your accounting is to generate SAF-T UA. Book a tax consultation.
Comments