E-Declaration Campaign 2026: New Clarifications from NACP

The 2026 e-declaration campaign is taking place under updated NACP clarifications, which significantly refine the approach to reporting assets, income and transactions, and also take into account new social benefits and the practice of previous years. Below are seven key changes that every declarant should consider when completing the declaration for 2025.

1. Updated general clarifications and structure of examples
   The NACP has updated the basic clarifications for the 2025 declaration campaign, added new examples and “key points”, and placed special emphasis on reporting financial liabilities, expenses, transactions, as well as operations with real estate, vehicles and monetary assets.
2. Social benefits “National Cashback” and “Winter Support”
   The NACP clarifications separately address the new income types “National Cashback ‘Made in Ukraine’” and “Winter Support”: since 25 December 2025 the Register automatically pulls in the source of income for these payments, which technically simplifies declaration but requires the declarant to verify the correctness of the data; such amounts must be reported as state income with the correct type of income and source in order to avoid discrepancies or complete non‑reporting of these payments in the declaration.
3. More detailed rules for declaring property and transactions
   The updated NACP materials explain in detail how to declare transactions, expenses and financial liabilities, supplementing the clarifications with practical case studies (purchase/sale of real estate, mortgages, cars, major cash payments, deposits) and clearly indicating when a transaction is treated as an expense and when it is a liability; separate guidance is provided on co‑ownership to ensure that declarants correctly report their shares in property and do not confuse the full value of an asset with their own share, thereby reducing the risk of the data being treated as inaccurate.
4. Focus on monetary assets and declaration thresholds
   The clarifications and additional NACP information materials specify the thresholds from which monetary assets must be declared and when a notification of significant change in financial status is required. For 2026, the total amount of monetary assets subject to disclosure (cash, funds on accounts, e‑money, etc.) must exceed 50 subsistence minimums for able‑bodied persons — UAH 166,400 as of the end of the reporting period.
   It is also reiterated that a notification of a significant change in financial status must be filed if the declarant receives income, acquires property or makes an expenditure exceeding the same threshold of UAH 166,400, and this must be done within 10 days from the date of the transaction. These clarifications aim to eliminate the common mistake when declarants rely on outdated thresholds or “round” amounts, assuming that certain transactions may be omitted.
5. Opening foreign currency accounts and foreign exchange operations
   Another block of the updated clarifications concerns foreign currency accounts in non‑resident banks and foreign exchange operations. The NACP reminds that declarants are obliged to submit a special notification about opening such an account in a foreign bank within 20 days from the opening date or from the day they became aware of the account. This obligation exists in parallel with filling out the relevant section of the declaration, where such accounts and the funds on them must also be reported.
   The updated materials also detail how to declare funds held abroad, how to correctly reflect transfers between accounts in different currencies, exchange rate differences and other typical situations for public officials who have income or assets outside Ukraine. Clearer guidance reduces the risk that failure to declare foreign accounts will be justified by “misunderstanding” the rules.
6. Clarifications on the scope of declarants and when to file
   The NACP’s communication materials for the 2026 campaign once again stress who is required to submit an annual declaration for 2025 and in which cases a declaration is not required. The declaration campaign for public officials runs until 31 March 2026 inclusive; it applies to persons defined in Article 3 of the Law “On Prevention of Corruption” who held the relevant positions at the end of 2025 or ceased to hold them during the year.
   The clarifications also include specific guidance for special categories — military personnel, mobilised staff of public authorities, persons on parental leave or in prolonged absence due to the war. For some of these individuals, deferrals or simplified procedures apply, but the NACP recommends that, in case of doubt, they contact the relevant anti‑corruption officers or consult the Knowledge Base for individual clarifications.
7. New formats of methodological support and webinars
   For 2026 the NACP has supplemented its clarifications with an expanded package of methodological materials (step‑by‑step guides, videos, online tools) that are freely available in the Knowledge Base and on the training platform, and has also organised a series of webinars “Electronic Declaration 2026”, where experts explain common mistakes, provide practical advice and describe how automated control, checks and further NACP actions work after a declaration is submitted.
   If you have questions or issues related to filing your e‑declaration for 2025, interpreting the updated NACP clarifications or assessing the risk of liability for possible errors, seeking qualified legal assistance will help protect you from violations and reputational consequences.
   Author: Ihor Yasko, Managing Partner at “WINNER Law Firm”, PhD in Law.