The Cabinet is changing its approach to inspections: focus on risk management

The Cabinet of Ministers of Ukraine is changing its approach to inspections, emphasizing risk management as the strategic basis for reforming the system of state supervision. This approach is increasingly used in developed European countries, and Ukraine is now integrating these mechanisms to improve efficiency, reduce administrative pressure on businesses, and foster a transparent economic environment.

From Moratorium to Selective Control
In 2025, against the backdrop of martial law and a critical phase of economic transformation, the President and Cabinet launched a new wave of changes in business oversight. The key focus is a selective approach to inspections, based on risk orientation. Prior to 2025, Ukraine had already applied risk-based planning for tax audits, but these mechanisms were not comprehensive and often lacked proper practical implementation.

Presidential Decree No. 538/2025 and the related NSDC resolution provide for a moratorium on unwarranted business inspections. For businesses, this means shifting from mass inspections to a model where control is applied only to companies with a high risk of violations. Inspections for economic entities with Authorized Economic Operator (AEO) status or low risk are significantly restricted.

What is Risk Management in Supervision
A risk-oriented approach assumes that all inspections must result from an objective risk assessment, not just a formal presence on the inspection schedule. State agencies analyze business activity data, sectoral trends, and violation indicators to create inspection schedules prioritizing suspicious or “problematic” enterprises.

This system is based on:

• Using corporate and sectoral statistics for early identification of risk factors (opacity in reporting, financial instability, suspicious cross-border transactions, etc.);
• Digitization of procedures – integrating risk monitoring into automated platforms (including the Integrated Automated State Supervision System);
• Synchronizing the actions of various supervisory and financial agencies to avoid duplication of functions.

Impact on Businesses: What Will Change
The new Cabinet policy brings Ukraine closer to EU standards, where inspections are targeted and do not create unnecessary pressure for compliant businesses. The biggest beneficiaries are companies with a low-risk profile and those with AEO status, as they can only be scheduled for inspections if there are substantial grounds.

Meanwhile, for businesses in the “risk zone,” control will become stricter. This concerns excisable goods, smuggling, and tax evasion. Through automatic analysis of financial statements, transactions, and data from information systems, tax and customs bodies focus on “problematic” areas. As a result, unscrupulous businesses are under constant monitoring, and inspections may become more in-depth.

Administrative Changes and System Digitization
A crucial part of the reform is digitizing inspection coordination mechanisms. The Cabinet has committed to launching integrated supervisory modules, where information on scheduled and unscheduled inspections is synchronized between agencies.

Such coordination platforms will:

• Prevent duplication of inspections by different supervisory institutions;
• Reduce administrative costs for businesses;
• Rapidly inform enterprises of planned inspections;
• Ensure transparency and simplified procedures.

Tax authorities plan inspections annually, while customs authorities plan quarterly. The State Financial Inspection also forms its quarterly plan, considering customs and tax administration data, allowing for better allocation of control system resources.

Expected Effects and Challenges
Introducing a risk-oriented approach offers several advantages:

• Reducing unwarranted inspections and administrative burden;
• Optimizing state expenses and resources;
• Increasing business trust in the state and improving Ukraine’s investment appeal;
• Forming a transparent, competitive ecosystem focused on rule of law and self-regulation.

Risks include the imperfection of risk analysis algorithms, misidentification of risk profiles, or insufficient data digitization. To prevent abuses, the Cabinet implements regular audits and updates the regulatory framework.

Outlook for Ukraine’s Market in 2026
Changing the inspection approach places significant responsibility on businesses – companies must monitor their transparency and ensure corporate and tax policies comply with standards of integrity. This encourages internal organizational changes, development of risk self-assessment mechanisms, and quality internal auditing.

At the same time, deregulation by restricting inspections for low-risk businesses opens new opportunities for SMEs, accelerates business activity, and promotes job creation.

Conclusions
Reforming the supervision system by the Cabinet of Ministers of Ukraine in 2025–2026 is a systematic shift from total inspections to intelligent risk management, reflecting the world’s best practices. The effectiveness of this model depends on the quality of digital platforms, risk analysis methodology, and the dialogue between state and business.

Company owners have solid reasons to monitor their own risk profiles, as self-control and transparency are becoming the new guarantees of stable operations. The Ukrainian market is approaching a modern European model of interaction between supervisory agencies and businesses, with an emphasis on partnership, transparency, and responsibility.

Author — Maksym Bahniuk, Head of Tax and Customs Law Practice, Law Firm “WINNER”.