The Tax Service has updated the audit plan for 2026: who will be audited first

At the end of 2025, the State Tax Service published a new schedule of documentary planned audits for 2026, which has already been amended. For businesses, this means not only the appearance of a list of “candidates” for a visit from tax inspectors, but also a strengthening of the risk‑based approach: the focus of control remains on taxpayers with a higher probability of violations and significant potential additional tax assessments.

Regulatory framework and general rules

The annual audit schedule is drawn up and published in accordance with the Tax Code of Ukraine and the Procedure for forming the audit schedule approved by Order of the Ministry of Finance No. 524. The basic rule is that the initial schedule must appear on the STS website no later than 25 December of the previous year. At the same time, the legislation allows the STS to periodically update the schedule during the year, so even if a business was not included in the “first wave”, it may appear in the list during one of the subsequent updates.

Structure of the 2026 audit schedule

The STS audit schedule consists of four sections: documentary planned audits of legal entities, financial institutions and permanent establishments of non‑residents, individuals, as well as audits regarding personal income tax, the military levy and the single social contribution. For 2026, it includes almost 4.6 thousand entities – legal entities and private entrepreneurs; the number of audits is slightly lower compared to the previous year, which indicates a focus on the “quality” of control measures. The updated Sections I and II concerning legal entities and the financial sector confirm that these taxpayers remain at the center of the STS’s attention, and further adjustments during the year may significantly change their number in the schedule.

Risk‑based approach: how taxpayers are selected

The key trend is the formation of the audit schedule on the basis of a risk‑based approach enshrined in the Tax Code of Ukraine and Procedure No. 524. The State Tax Service states that it audits taxpayers with a high probability of violations and significant potential underpayments, using sectoral and industry analysis as well as analytics by specific types of activities. In practice, the schedule includes taxpayers with a set of “risk signals”: systemic losses with significant turnover, sharp fluctuations in indicators, atypical profitability for the industry, participation in risky supply chains, active use of tax benefits, etc.

Updating the schedule: trends for 2025–2026

The experience of 2025 showed that updating the audit schedule has already become routine practice for the State Tax Service, and the changes can be quite substantial: within a single year the schedule was revised three times, and the number of planned audits of legal entities increased with each update. This dynamic continues in the transition to 2026: the year‑end 2025 update allowed the tax authorities to adjust the list of taxpayers, taking into account new financial and tax reporting data, the results of risk analysis and experimental tax risk management projects. For businesses, this means that the “out of plan” status is purely temporary: inclusion in or exclusion from the schedule is a dynamic process in which the current state of settlements with the budget, the behaviour of counterparties, and the company’s response to requests from the authorities play a crucial role.

What the updated plan means for taxpayers

The updated audit plan for 2026 indicates that tax control is gradually shifting from a “mass” to a more targeted format focused on taxpayers with higher tax risk. The actual reduction in the total number of planned audits should not be perceived as a relaxation of pressure: on the contrary, in each specific audit the tax authorities expect to detect significant violations, so the depth and detail of control measures may increase. At the same time, the transparency of selection criteria and the predictability of the publication deadlines for the plan formally create an opportunity for preventive preparation, both in terms of analysing one’s own indicators and in terms of legal support for potential disputes.

How businesses should respond to the updated plan

A rational response to the update of the audit schedule involves several steps. First, businesses should regularly check whether they are included in the published STS plan, rather than limiting themselves to a one‑off check in December, given the possible adjustments during the year. Second, it is necessary to build an internal tax risk monitoring system: analyse key indicators, track anomalies compared to the industry, and conduct preventive audits of specific transactions and counterparties. Third, if a business is included in the plan, it is advisable to prepare a “taxpayer dossier” in advance: organise primary documents, identify “weak spots”, and prepare a defence position in case of additional assessments and disputes.

Prospects for tax control in 2026

The updated audit plan and the emphasis on a risk‑based approach indicate a move towards analytical rather than purely formal control, where the taxpayer’s indicators are considered in the context of the market and the behaviour of counterparties. As the State Tax Service develops its analytical tools, it will strengthen the interconnection between tax, financial and non‑financial information and expand the use of tax risk management projects, the results of which have already been taken into account when forming the 2026 audit schedule. For compliant taxpayers, this is an additional incentive to invest in the transparency of the business structure, the quality of accounting and tax planning, as these factors are becoming the main “safeguards” against being classified as high‑risk.

If you have any questions or issues related to your business being included in the audit plan, preparing for a visit from tax inspectors, appealing audit results, or building a tax risk management system, it is advisable to engage professional legal and tax support in advance.

Author: Ihor Yasko, Managing Partner of the law firm “WINNER”, PhD in Law.