E-Audit and SAF-T UA: new standards of tax reporting

In the digital age, tax administration is gradually moving away from paper declarations and reports, shifting instead towards automation, transparency, and electronic data exchange. Ukraine is not standing aside from global trends: with the introduction of e-audit and the SAF-T UA format, the state is taking a step toward modernizing the interaction between business and tax authorities.

The new reporting standards are aimed at unifying tax information, ensuring its fast and efficient processing, and reducing the risks of errors and fraud. At the same time, for businesses this means the need for a deeper understanding of digital requirements, IT system adaptation, and greater transparency of financial reporting.

This article examines what SAF-T UA and e-audit are, how these tools will affect companies in Ukraine, and what should be taken into account today to prepare successfully for the new requirements.

What is e-audit in Ukraine?

Electronic audit (e-audit) is a modern form of tax inspection based on automated analysis of a taxpayer’s electronic data without the need for tax inspectors to visit the enterprise. In Ukraine, e-audit is being introduced as part of the tax control digitalization reform.

The main idea of e-audit is the use of electronic reporting formats, in particular SAF-T UA, which contain structured and detailed data on accounting, tax operations, and financial flows of the enterprise. This enables the State Tax Service (STS) to promptly and effectively analyze and identify risks without lengthy on-site inspections.

Currently, e-audit in Ukraine is applied in pilot mode for large taxpayers that have signed the relevant agreements with the STS. Over time, it is expected to expand to medium and small businesses.

What is SAF-T UA?

SAF-T UA (Standard Audit File for Tax – Ukraine) is an electronic format for exchanging tax and accounting information between businesses and regulatory authorities. It is based on the international SAF-T standard, developed by the Organisation for Economic Co-operation and Development (OECD) to unify approaches to tax audits in a digital environment.

The SAF-T format provides for the transfer of data directly from a company’s accounting systems in the form of XML file structures that contain detailed information on financial and business transactions, accounting entries, tax invoices, account balances, settlements, and more.

Regulatory framework for the implementation of SAF-T UA

The development and introduction of SAF-T UA in Ukraine is based on a number of key regulatory acts that form the legislative foundation for digital tax control:

1. Law of Ukraine “On Electronic Documents and Electronic Document Flow” — defines the legal status of electronic documents, the principles of their legal force, and the conditions of electronic document circulation between taxpayers and state authorities.
2. Article 85.2 of the Tax Code of Ukraine (TCU) — grants the tax authority the right to receive electronic copies of primary documents, accounting, and statistical reports during audits.
3. Order of the Ministry of Finance of Ukraine No. 1393 of 07.11.2011 “On Approval of the Procedure for Providing Documents of Large Taxpayers in Electronic Form” — establishes the technical requirements for electronic submission of documents, including financial statements.
4. Order of the Ministry of Finance No. 561 of 01.09.2020 — amends Order No. 1393, adapting procedures for the implementation of e-audit and SAF-T UA format.
5. Concept for the Implementation of Electronic Audit for Taxpayers — a strategic document developed by the STS, which outlines the stages, approaches, and tools for launching digital audit.
6. SAF-T File Guide and Schema (version 2.0) — technical documentation describing the structure of the SAF-T UA file, field formats, data types, and the procedure for their generation from taxpayers’ accounting systems.
7. Order of the Ministry of Revenues and Duties of Ukraine No. 729 “On Approval of the Format (Standard) of the Electronic Reporting Document of a Business Entity” — defines the requirements for electronic documents generated and submitted by taxpayers within the framework of SAF-T and e-audit.

Who must prepare and submit SAF-T UA?

• The obligation currently applies only to large taxpayers starting from January 1, 2025. They must prepare and submit the SAF-T UA file at the request of the tax authorities within the framework of e-audit procedures (i.e., as part of a tax inspection).
• Submission by other VAT payers is planned from January 1, 2027.

What data is transmitted in the SAF-T UA file?

The SAF-T UA format provides for the most detailed export of a company’s accounting data directly from its accounting system. It is not about formal reporting but a full “mirror” of accounting, including operational, financial, and tax data with breakdowns for each business transaction.

The structure of the SAF-T UA file contains the following information blocks:

• Counterparty data (full list of buyers and suppliers with details: name, registration code/Tax ID, legal/actual address, contacts).
• Goods and services nomenclature (product/service name, SKU, code, unit of measurement, purchase/sale prices, category grouping).
• Sales and purchases (volumes, dates, primary documents, VAT-inclusive and exclusive amounts).
• Inventory and warehouse turnover (opening/closing balances, inflows and outflows, internal warehouse transfers).
• Accounts receivable/payable (balances, overdue terms, payment history).
• Cash flow (cashless/cash payments, internal fund transfers, bank statements).
• Fixed assets accounting (acquisition, commissioning, depreciation, disposal, revaluation, book value).
• General ledger and tax adjustments (full postings by accounts, data for financial and tax reporting, adjustments according to tax rules).
• Accounting policy (description of principles, valuation methods, depreciation methods, etc.).
• Business transactions with details (date, number, amount, document type, description, reference to primary document, related accounts).

In fact, SAF-T UA is a complete snapshot of a company’s accounting database, allowing the tax authority to analyze transactions without an on-site audit. Such a level of detail requires enterprises to maintain high-quality accounting, accuracy, consistency of data, and technical readiness of systems.

How is SAF-T UA submitted: request and submission procedure

The procedure for submitting SAF-T UA in Ukraine is currently carried out only upon request of the tax authority within the framework of electronic audit.

1. Request sent to the taxpayer
   The request for SAF-T UA submission is sent by the STS of Ukraine via the taxpayer’s electronic cabinet. The request contains: the basis for the audit, the deadline for submission, and the reporting period.
   Requests are sent only to companies that:

• belong to the category of large taxpayers,
• have signed a Memorandum of participation in the e-audit pilot project with the STS.

2. SAF-T UA file generation
   The responsible persons of the company generate the SAF-T UA file in XML format according to:

• SAF-T UA structure version 2.0;
• approved technical XSD schemes;
• the company’s accounting policy.

3. Submission to the STS

• Submission is carried out via the Taxpayer’s Electronic Cabinet or other compatible software.
• Before submission, the file is signed with a Qualified Electronic Signature (QES) of an authorized person.
• After submission, the STS automatically generates a receipt confirming acceptance or reports technical/logical errors.

4. Data processing and analysis by the tax authority
   After receiving SAF-T UA, the STS system automatically analyzes the data. Inspectors can generate reports, compare indicators, identify unusual operations, detect discrepancies or risks (e.g., unjustified tax benefits, dealings with “risky” counterparties).

Based on the analysis, the STS may:

• close the audit without an on-site inspection if no violations are found;
• initiate additional requests or an on-site inspection.

Submission deadlines and penalties

The deadline for SAF-T UA submission is indicated in the STS request and is usually 3 to 10 business days.

In case of late submission or refusal — after the implementation of legislative changes (draft law No. 6255), penalties may apply:

• 100 minimum wages (MW) — for large taxpayers,
• 10 MW — for other VAT payers.

Penalties double if the obligation is not fulfilled within 30 days after notification. However, if submission/correction occurs within 30 days, penalties are not applied.

Currently, there is no liability for non-submission of SAF-T UA files, since implementation is still in the testing phase for all taxpayers.

Which countries already use the SAF-T reporting format?

SAF-T (Standard Audit File for Tax) is already widely used or being implemented in many countries, mainly in Europe.

Countries where SAF-T is in use:

• Portugal — since 2008, currently in updated SAF-T (PT) version.
• Poland — since 2020, SAF-T (JPK) is mandatory for all VAT payers.
• Lithuania — mandatory for all businesses since 2020.
• Norway — mandatory since 2020 for companies using electronic accounting systems.
• Romania — since 2022 mandatory for large companies, since 2023 for medium, and from 2025 for small.
• France — used for audits but not regular reporting; from 2024 planned full integration with e-invoicing.
• Hungary — mandatory implementation planned from January 2026, currently in preparation.

Countries in pilot/implementation stage:

• Slovakia, Czech Republic, Slovenia — conducting technical preparation or testing, but no mandatory rollout yet.
• Croatia — studying international experience and preparing regulatory framework.

The implementation of SAF-T UA and e-audit is an important step in modernizing tax reporting in Ukraine. These tools allow tax authorities to gain deep and structured access to company accounting data, significantly increasing control efficiency and reducing the need for traditional on-site inspections.

For businesses, SAF-T UA is both a challenge and an opportunity: requirements for data quality, transparency, and digital readiness are increasing, but at the same time new ways to optimize tax processes and reduce audit risks are emerging.

As of today, SAF-T UA is mainly applied to large taxpayers upon request from tax authorities. However, in the coming years, the format will gradually extend to medium and small businesses. Therefore, timely adaptation of accounting systems and staff training are the key to successful integration of these new standards.